Per T.J. Joice, A.M.—As these appeals involve identical issues, they are disposed of by a common order for the sake of convenience. The assessment years involved are 1982-83 to 1986-87 (both inclusive). The appeals by the assessee are directed against the orders of the CIT(A), Belgaum, dated 31-12-1992, in which he has upheld the Gift-tax assessments made for these years by the Assessing Officer.

2. The assessee firm is doing the business of running a cinema theatre, exhibiting and distributing films, taking cinema theatres on hire/lease and other connected activities. While doing the IT assessment, the ITO noticed that the assessee had kept huge amounts in deposits with its sister concern M/s. Raikar Entertainments, but it had not claimed or received any interest on these deposits. Therefore, the Assessing Officer concluded that the assessee had forgone its right to receive interest on the deposits without adequate consideration and hence, he treated it as a deemed gift and initiated GT proceedings against the assessee. The assessee, however, filed nil returns of gift and pleaded before the Assessing Officer that there was no deemed gift. In consideration of keeping deposits f