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A.D.JAIN, J.SUDHAKAR REDDY
Ericsson AB – Appellant
Versus
Deputy Director of Income-tax, International Taxation, Circle 1(2), New Delhi – Respondent
J. Sudhakar Reddy, Accountant Member - All these appeals are filed by the assessee and are directed against a common order passed by the CIT(A)-XI, New Delhi dated 23.2.2011 for the A.Ys 1999-2000 to 2004-05.
2. As both parties submitted that the issues are common in all these appeals, for the sake of convenience they are heard together and disposed off by way of this common order.
3. The facts of the case as brought out by the A.O. at paras 1,2,3,4 and 5 of the assessment order which is extracted for ready reference.
"1. The assessee, M/s Ericsson Radio Systems AB, is a company incorporated in Sweden and is a tax resident of Sweden. The company is a wholly owned subsidiary of Telefonaktiebolaget LM Ericsson, Sweden. The main business of the assessee is supply of GSM Mobile Telecommunication system comprising of hardware and software to various cellular companies operation in India (ICO's).
2. The assessee company was not filing its return of income in India. Pursuant to the notices sent by the ITO returns were filed. The return of income for this year was filed on December 4,2001 declaring NIL income. Notice u/s 148 was issued on October 4,2002. Vide letter dated 17.10.2002, it w
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