Vibhu Bakhru, J.

1. Nortel Networks India International Inc. (hereafter ‘the Assessee’) has preferred the present appeals under Section 260A of the Income Tax Act, 1961 (hereafter ‘the Act’) against orders passed by the Income Tax Appellate Tribunal (hereafter ‘ITAT’). ITA Nos. 669/2014, 671/2014 and 672/2014 are appeals preferred by the Assessee against a common order dated 13th June, 2014 passed by the ITAT in ITA Nos. 1119, 1120 and 1121/Del/2010, which were appeals preferred by the Assessee against a common order dated 22nd December, 2009 passed by the Commissioner of Income Tax (Appeals) [hereafter 'CIT(A)'] in respect of Assessment Years (AYs) 2003-04, 2004-05 and 2005-06. The common order dated 22nd December, 2009 passed by CIT(A) disposed of the appeals preferred by the Assessee against two separate assessment orders both dated 18th December, 2006 passed by the Assessing Officer (hereafter 'AO') under Section 147 read with Section 143(3) of the Act in respect of the AYs 2003-04 and 2004-05 as well as an assessment order dated 31st December, 2007 passed by the AO in respect of assessment year 2005-06.

2. ITA Nos. 666/2014, 667/2014 and 673/2014 impugn a common order dated 13th June, 2014 passed by the ITAT in ITA Nos. 2177, 2178 and 2179/Del/2011 which were appeals preferred by the Assessee against a common order dated 20th January, 2011 passed by CIT(A) in appeals no.78, 79 and 77/2009-10. These appeals were preferred by the Assessee against separate orders dated 29th January, 2010 passed by the AO to give effect to the common order dated 22nd December, 2009 passed by CIT(A) for AYs 2003-04, 2004-05 and 2005-06.

3. ITA No. 689/2014 is directed against ITAT's order dated 13th June, 2014 passed in an appeal preferred by the Assessee against final order dated 17th August, 2011 passed by the AO under Section 144C of the Act in respect of AY 2008-09.

4. By an order dated 24th February, 2015, ITA Nos. 666/2014, 667/2014 and 673/2014 were admitted and the following questions of law were framed:-

"(i) Whether the Tribunal erred in concluding that the Appellant had a Permanent Establishment (PE) within the meaning of Article 5 of the Double Taxation Avoidance Agreement (DTAA) between India and USA?

(iii) Whether the finding of the Tribunal that the Appellant had a PE in India is perverse and contrary to the facts and material on record?"

5. ITA Nos. 671/2014, 672/2014 and 669/2014 were admitted on 24th February, 2015 and the following questions of law were framed:-

“(i) Whether the Tribunal erred in concluding that the Appellant had a Permanent Establishment (PE) within the meaning of Article 5 of the Double Taxation Avoidance Agreement (DTAA) between India and USA?

(ii) Whether the Tribunal erred in affirming that the Appellant had a PE (fixed place PE and dependent agent PE) in India in terms of the Liaison Office of Nortel Canada and also in terms of the Nortel Networks (India) Private Ltd" (being installation and service PE)?

(iii) Whether the finding of the Tribunal that the Appellant had a PE in India is perverse and contrary to the facts and material on record?

(iv) Whether, without prejudice, the Tribunal erred in attributing 50% of the alleged profits to the alleged PE of the Appellant in India and whether such approach and quantification was inconsistent with Article 7 of the DTAA?”

6. Similarly, ITA No. 689/2014 was also admitted on 24th February, 2015 and the following questions of law were framed:-

“(i) Whether the Tribunal erred in concluding that the Appellant had a Permanent Establishment (PE) within the meaning of Article 5 of the Double Taxation Avoidance Agreement (DTAA) between India and USA?

(ii) Whether the Tribunal erred in affirming that the Appellant had a PE (fixed place PE and dependent agent PE) in India in terms of the Liaison Office of Nortel Canada and also in terms of the Nortel Networks (India