आदेश /ORDER

PER SANDEEP GOSAIN, JM:

The present appeals have been filed by the Revenue challenging the different impugned orders dt. 12.06.2025 passed under section 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre (NFAC) / CIT(A) for the assessment years 2006-07 to 2011-12.

2. Since all the issues involved in these appeals are common and identical and belongs to one assessee therefore, they have been clubbed, heard together and consolidated order is being passed. Firstly, we shall take ITA No. 5385/Mum/2025, A.Y 2006-07 as lead case and facts narrated therein.

ITA No. 5385/Mum/2025, A.Y 2006-07

The ground of appeal as raised by the Revenue:

“1. "On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in holding that the assessee is "wholly or substantially financed by the Government within the meaning of section 10(23C)(iiiab), by considering non-recurring elements such as capital grants, land, and infrastructure, which are neither recurring nor reflected in the Income & Expenditure Account."

2. "On the facts and circumstances of the case and in law, the Ld. CIT(A), NFAC erred in holding that the term "substantially financed by the Go