JUDGMENT

Manmeet Pritam Singh Arora, J. Present appeal has been filed by the Revenue under Section 260A of the Income Tax Act (`Act') challenging the order dated 10th November, 2021 passed by the Income Tax Appellate Tribunal (`ITAT') in ITA No. 5781/Del/2017 for the Assessment Year (`AY') 2004-05.

2. Briefly stated, the pertinent facts are that, the Assessee is engaged in the business of network design, management, communication, connectivity services and related products. The Assessee filed its return of income for the relevant year on 30th October, 2004 declaring an income of Rs.29,30,15,180/-, however, the income of the Assessee was assessed at Rs.32,15,72,740/- by the Assessing Officer (`AO') vide original assessment order dated 28th December, 2006.

2.1. Aggrieved by the said order, the Assessee filed an appeal before the Commissioner of Income Tax (Appeals), [`CIT(A)'], which upheld the order of the AO and confirmed the additions. Thereafter, an appeal arose before the ITAT and the Tribunal vide its order dated 30th September, 2014, set aside the original assessment order dated 28th December, 2006, and restored the matter to the file of the AO for determining the issue of