R.C. Sharma, Accountant Member. - These are three appeals filed by the assessee against the separate orders of CIT (Appeals) dated 8-2-2003, 17-2-2003 and 8-2-2005 for the assessment years 2002-03, 2003-04 and 2001-02, in the matter of order passed under sections 154/143(i) of the Income-tax Act, 1961 wherein following grounds of appeal have been raised :

Grounds in ITA No. 2436/Delhi/05 :

"1. That the impugned appellate order dated 8-2-2003 (sic) passed by the learned CIT (Appeals) is bad in law and wrong on facts.

2. That on the facts, circumstances and legal position of the case, the learned CIT (Appeals) has erred in law in holding that the appellant has claimed credit for TDS for the first time by filing application under section 154 of the Income-tax Act dated 15-5-2004 and before that no claim for credit for TDS has been made at any point of time.

3. That on the facts, circumstances and legal position of the case, the learned CIT (Appeals) has erred in law in not allowing credit for tax deducted at source amounting to Rs. 2,18,15,062 attributable to interest income offered and subjected to tax in the year under appeal.

4. Without prejudice to Ground No. 3 hereinabove, the learned CIT (Appeals) has erred in law in not considering and allowing credit for the entire amount of tax deducted at source amounting to Rs. 3,29,90,648 in assessment year 2003-04 when the deductee had provided for interest & deducted TDS.

5. That the appellant craves to reserve to itself the right to add, alter, amend, substitute, withdraw and/or vary any ground(s) of appeal of or before the time of hearing."

Grounds in ITA No. 2437/Delhi/05 :

"1. That the impugned appellate order dated 17-3-2003 (sic) passed by the learned CIT (Appeals) is bad in law and wrong on facts.

2. That on the facts, circumstances and legal position of the case, the learned CIT (Appeals) has erred in law in holding that the appellant has claimed of TDS by filing original certificate by way of application under section 154 of the Income-tax Act to substantiate the claim of TDS already made in the return of income is not a mistake apparent from record which can be rectified.

3. That on the facts, circumstances and legal position of the case, the learned CIT (Appeals) has erred in law in not allowing credit for tax deducted at source amounting to Rs. 35,68,320 attributable to interest income offered and subjected to tax in the year under appeal.

4. Without prejudice to Ground No. 3 hereinabove, the learned CIT (Appeals) has erred in law in not considering and allowing credit for the entire amount of tax deducted at source amounting to Rs. 3,29,90,648 during the year under reference when the deductee had provided for interest and deducted TDS.

5. That the appellant craves leave to reserve to itself the right to add, alter, amend, substitute, withdraw and/or any ground(s) of appeal at or before the time of hearing."

Grounds in ITA No. 2464/Delhi/05 :

"1. That the impugned appellate order dated 8-2-2005 passed by the learned CIT (Appeals) is bad in law and wrong on facts.

2. That on the facts, circumstances and legal position of the case, the learned CIT (Appeals) has erred in law in holding that the appeal filed before her is not maintainable.

3. That on the facts, circumstances and legal position of the case, the learned CIT (Appeals) has erred in law in not considering and allowing credit for tax deducted at source amounting to Rs. 76,06,766 attributable to interest income offered and subjected to tax in the year under appeal.

4. Without prejudice to Ground No. 3 hereinabove, the learned CIT (Appeals) has erred in law in not considering and allowing credit for the entire amount of tax deducted at source amounting to Rs. 3,29,90,648 in the assessment year 2003-04 when the deductee had provided for interest and deducted TDS.

5. That the appellant craves leave to reserve to itself the right to add, alter, amend, substitute, withdraw and/or any ground(s) of appeal at or before the time of hea