आदेश/ORDER

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This bunch of eight appeals filed by the Department as well as different assessees are directed against different orders passed by the ld. Commissioner of Income Tax (Appeals), Coimbatore-3, Coimbatore, for the assessment years 2017-18, 2018-19 and 2020-21.

2. Since, the issues raised in these appeals are similar based on the same identical facts, with the consent of both the parties, we proceed to hear all the appeals together and pass consolidated order for the sake of convenience.

3. Both the parties have agreed that the appeal of the Revenue in ITA No. 3326/Chny/2019 for AY 2017-18 can be heard as lead case as the facts and circumstances therein covers all the appeals. Therefore, we proceed to take-up the said appeal as lead case.

I.T.A. No. 3326/Chny/2019 for AY 2017-18

4. Ground No. 1 consisting of sub-grounds (i) & (ii) raised by the Revenue and the same are reproduced hereunder:

i) Whether on the facts and circumstances of the case and in law the ld. CIT(A) is justified in holding that incentive of ₹.27,28,00,467/- given by the Govt to the assessee for exploring new market is a capital receipt, whereas the object of the incen