N. Kumar, J.—The Revenue has preferred these appeals challenging the order dated 28.05.2008 passed by Income Tax Appellate Tribunal, Bangalore allowing the appeal filed by the assessee. These eight appeals are taken up for consideration together as a common question of law is involved between the same parties but in respect of different assessment years and therefore, they are disposed of by this common order.

2. The assessee is a world known name or brand in sports apparels. It has its main office in USA. It has various associated enterprises or subsidiaries in various parts of the world. The assessee from its office in USA arranges for all its subsidiaries all over the world the various brands of sports apparels for sale to the various customers. The arrangement is through procurement by manufacture from the manufacturer, who directly dispatches the apparels to the various subsidiaries spread all over the world. The assessee with a view to spread its wings mainly from the point of view of procurement of various apparels by manufacture with the assistance of various manufacturers from the various parts of the world approached the Reserve Bank of India to allow it to open a