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By way of this order, we shall dispose of ITA No. 269 of 2014 titled as 'Telelinks Vs. Commissioner of Income Tax, Bathinda' and ITA No. 225 of 2014 titled as 'The Commissioner of Income Tax-II, Amritsar Vs. M/s The Mattewal Co-op. L/C Society, Amritsar.

Before delimiting the substantial questions of law that arise for adjudication, it would be appropriate to briefly refer to the facts of each case.

Ess. Buildings (P) Ltd., Ludhiana, (ITA No. 707/Chd./1997) Aggrieved by the assessment order, the assessee filed an appeal. The Commissioner of Income Tax (Appeals) (hereinafter referred to as the 'CIT(A)'), Bathinda reduced the net profit rate to 6%. The revenue filed an appeal before the Income Tax Appellate Tribunal (here-in-after referred to as the 'ITAT'). The ITAT accepted the appeal, set-aside the order passed by the CIT(A) and restored the order passed by the Assessing Officer applying a net profit rate of 12%.