1. These eight appeals are cross appeals filed by the assessee and by the Revenue. The relevant assessment years are 2000-01, 2001-02, 2002-03 and 2005-06. These appeals are directed against the common order of the Commissioner of Income-tax (Appeals)-V at Chennai passed on March 31, 2009. The appeals for the assessment years 2000-01, 2001-02 and 2002-03 arise out of the assessments completed under section 143(3) read with section 147 of the Income-tax Act, 1961. The appeal for the assessment year 2005-06 arises out of the regular assessment completed on section 143(3) of the Act.

2. The assessee, M/s. Sivagami Holdings P. Ltd. is a closely held company incorporated in India in August, 1998. In the year 2000 the assessee-company became part of a reconstruction scheme of M/s. M. Ct. M. Corporation P. Ltd. The reconstruction scheme actually envisaged a process of demerger. As a result of this corporate exercise, the assets and liabilities of M/s. M. Ct. M. Corporation got vested in the hands of the assessee-company and in the hands M/s. M. Ct. M. Global Investments. The demerged company M. Ct. M. Corporation had business assets in India and in Malaysia. In pursuance of the scheme