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1. These 12 appeals which arise from the respective orders of the learned CIT(A) in connection with the proceedings under Section 201(1) and 201(1A), involving common facts, are disposed of by this common order.

2. The facts, briefly stated, are that the assessee bank is a fully owned public sector undertaking of Government of India, with large number of employees. In its capacity as an employer, the assessee bank is obliged to deduct tax at source under Section 192 of the Act in respect of salaries and other amenities or perquisites granted to the employees. The dispute relevant for the present appeals pertains to the alleged default of non-deduction of tax on the value of the perquisites granted to the employees during the financial years 1995-96 to 2000-01 (referred to by the Assessing Officer as assessment years 1996-97 to 2001-02). During the above mentioned financial years, the assessee bank provided furniture to different categories of employees. The items of furniture included computer table & chair, vaccum cleaner, coir mattresses, cooking range, TV, washing machine, refrigerator, dining table with chairs, air conditioner etc. In respect of these various items of furniture and other appliances granted to the employees, the assessee bank charged standard rent based upon the first stage of pay scale of different categories of employees. During the financial years under appeal, the assessee bank was initially charging rent at the rate of 1 per cent of the first stage of the scale in which the employee was placed, on the basis of the internal circular dated 1-11-1992. Subsequently, by another circular, the rent was reduced to 0.5 per cent with effect from 1-4-1998. The assessee bank also reimbursed to the employees, the expenditure incurred by them on daily wages for maintenance and proper upkeep of the residential accommodation, furniture and fixtures owned by the assessee bank and allotted to the employees. The reimbursement was at a fixed rate on the basis of internal circulars issued by the bank from time-to-time and the reimbursement was allowed on the strength of prescribed certificates filed by the concerned employees. The assessee bank also reimbursed to the employees, who were allotted residential accommodation and furniture etc., the expenditure incurred on cleansing material on production of certificates accompanied by bills by the concerned employees on monthly basis. This reimbursement was subject to the maximum limits fixed from time to time.

14. It is contended that the assessee bank has been following uniform policy regarding charging of standard rent from different categories of officers and full explanation was submitted before the learned CIT(A). It is also pointed out that the officers normally did not get the furniture at their full entitlement. He invited our attention to pages 62 and 63 of PB, where the concerned employees have stated that they have taken furniture at 1/3 of their entitlement. The learned Counsel also argued that the reimbursement of daily wages for casual labourer and for cleansing material was entirely for the maintenance and upkeep of the residential accommodation, furniture and fixtures etc. allotted to the employees and there can be no element of perquisite. The assessee-bank has taken all precautions to ensure that these reimbursements are not mis-used by the employees. He invited our attention to pages 58-61 of the PB, which contain sample copies of the claim for reimbursement for cleansing material made by the employees. At page 58 is the prescribed certificate signed by the employee claiming the reimbursement of a sum of Rs. 260 for the month of February, 1998. This certificate is accompanied by a bill dated 27-2-1998 in respect of purchase of the cleansing material. The daily wages are reimbursed by the assessee bank on the basis of certificates given by the employees, sample copies of which are at pages 62-63 of the PB. The learned Counsel contended that in any case, the assessee was under bona fide belief that there was no liability of deducting tax at source with regard to furniture, and reimbursement of casual labour charges and cleansing material. All such reimbursements were regulated and governed by internal circulars. The learned Counsel invited our attention to pages 28 and 29 of the PB, which contain copy of letter dated 2-6-2003 filed before the learned CIT(A). With regard to casual labour charges, the following submissions were made in this letter:

In respect of reimbursement of casual labour payments to officers, we enclose herewith internal Circular No. ADM : 11681, dated 22nd March, 1978, Circular DO No. ADM/3110, dated 24th January, 1983, DO No. ADM/SPL/2830, dated 18th September, 1992 and CD0/PM/16/CIR/1, dated 12th April, 2001 of the Bank (copies enclosed Annexures V, VI, VII & VIII respectively), which deals with reimbursement of casual labour expenses to the officers of the Bank. The circular states that the casual labourer provided to officers is not by way of perquisites to the officer, i.e., in the nature of personal servant for the officer but is in the nature of casual labourer employed for proper upkeep of the official residence, furniture, fittings etc. provided to him by the Bank.