Per G.D. Agrawal, Accountant Member - These cross-appeals for the two assessment years, namely, 1990-91 and 1991-92 are directed against the orders of the Commissioner of Income-tax (Appeals)-XV, New Delhi. Since common points are involved, they are being disposed of together for the sake of convenience.

ITA Nos. 6388/Del./1993 & 7041(Delhi)/1994 (Revenue’s appeals)-

2.1 These two appeals by the revenue are for assessment years 1990-91 and 1991-92. In these two appeals there is only one ground of appeal in each year, which reads as under:—

Ground of appeal in assessment year 1990-91:

" On the facts and in the circumstances of the case, the CIT (Appeals) erred in granting relief of Rs. 24,17,65,160 crores by deleting the addition made on account of amount credited to Delhi Administration and other Government Economic Services by holding that it was a case of diversion of income and not application of income."

Ground of appeal in assessment year 1991-92:

"On the facts and in the circumstances of the case, the ld. CIT (Appeals) has erred in considering the expenditure of Rs. 28.86 crores to Delhi Administration— Other General Economic Services’ as a diversion of income rather than an a