(Delivered by Hon'ble Sudhir Agarwal, J.)

1. Both these appeals filed under Section 260A of Income Tax Act, 1961 (hereinafter referred to as "Act 1961") have arisen from the same judgment dated 15.9.1999 passed by Income Tax Appellate Tribunal, Allahabad Bench 'A', Allahabad(hereinafter referred to as 'Tribunal) in ITA No. 1551(Alld) of 1997 relating to Block period from 1.4.1994 to 28.11.1996. Assessee as well as Commissioner of Income Tax (hereinafter referred to as 'Revenue') both have come in appeal before this Court and hence both appeals have been heard together and are being decided by this common judgment.

2. Sri Ravi Kant, Senior Advocate assisted by Sri Rahul Agarwal, Advocate have appeared on behalf of Assessee and Sri Manish Goel, Advocate has put in appearance on behalf of Revenue.

3. Revenue's appeal was admitted on the following substantial questions of law:-

(1) Whether on the facts and in the circumstances of the case, Tribunal was right in holding that authorization for search issued under section 132 and on the basis of which search was conducted