Sudhir Agarwal, J.

1. Heard Sri J.N. Mathur, learned Senior Advocate, assisted by Sri Mudit Agarwal, Advocate, for Assessee and Sri Manish Misra, Advocate, for Revenue.

2. These four appeals (except Sl. No.-5) have been filed under Section 260A of Income Tax Act, 1961 (hereinafter referred to as "Act, 1961") arising from judgments and orders of Income Tax Appellate Tribunal (hereinafter referred to as "Tribunal"). Three appeals are by Assessee, M/s Upper India Couper Paper Mills Co. Private Limited (hereinafter referred to as "Assessee") and one by Commissioner of Income Tax (hereinafter referred to as "Revenue"). The details of judgments of Tribunal, relevant Assessment Years (hereinafter referred to as "A.Y.") etc. are given in the following chart:

Sl.No.	I.T.A. No.	Date of Impugned judgment	I.T.A. No. Before Tribunal	Assessment Year
1	24 of 2012	07/08/12	154/LKW/2012	2007-08
2	25 of 2014	15.07.2014	52/LKW/2014	2007-08
3	121 of 2015	23.06.2015	62/LKW/2012	2008-09
4	120 of 2015	23.06.2015	301/LKW/2013	2009-10

3. There is a Writ Petition also, filed by Assessee, i.e., Misc. Bench No. 1812 of 2014 wherein petitioner has challenged Reference dated 10.10.2013 made by Joint Commissioner of Income Tax, Range-VI, Lucknow, i.e. Assessing Officer (hereinafter referred to as "A.O.") to District Valuation Officer (hereinafter referred to as "D.V.O.") and provisional valuation report dated 28.02.2014/03.03.2014 and 10.03.2014 submitted by DVO i.e. respondent-3.

4. ITA No. 24 of 2012 filed by Revenue was admitted on 08.10.2013 on following two substantial questions of law:

(A) Whether under the facts and circumstances of the case the Income Tax Appellate Tribunal has erred in believing that the Assessing Officer has taken a view in the light of surrounding circumstances which cannot be called to be erroneous and prejudicial to the interest of Revenue and Commissioner of Income Tax has exercised his jurisdiction under section 263 of Income Tax Act without having sufficient material with him.

(B) Whether Income Tax Appellate Tribunal has erred in law in directing that value of land as on 01.04.1981 be taken at Rs.95 per Sq. Ft. as the same is a hypothetical value adopted by Assessee on the basis of an auction held on 23.03.1985.

5. ITA No. 120 of 2015 and 121 of 2014, both, were admitted on 09.10.2015 on three substantial questions of law which are identical and reproduced from ITA 120 of 2015, as under:

(A) Whether finding recorded by Income Tax Appellate Tribunal to the effect that Registered Valuer has not scaled down value adopted from the exemplar of 1985 to arrive at the fair market value for the year 1981, is perverse and incorrect?

(B) Whether in the facts and circumstances of the case at hand, Income Tax Appellate Tribunal could have doubted correctness of Valuation Report of Registered Valuer without there being any fresh material on record, when it had upheld the said report in respect of the proceedings for Assessment Year 2004-05?

(C) Whether Income Tax Appellate Tribunal could have permitted Assessing Officer to refer the matter for valuation to DVO in spite of the fact that said Reference would be beyond the scope of such reference as laid down in Section 55-A of Income Tax Act, 1961?

6. ITA No. 25 of 2014 has not been formally admitted but as agreed by learned counsel for parties, following substantial questions of law have arisen, which need be adjudicated in this appeal:

(A) Whether Income Tax Appellate Tribunal being the last fact finding authority was justified in not recording any finding pertaining to Grounds H, I and J of memo of appeal filed before it, pertaining to applicability of doctrine of merger, raised by appellant in the memo of appeal, and in rejecting appeal merely after discussing only 7 out of 10 grounds raised?

(B) Whether order of Income T