JUDGMENT

VIBHU BAKHRU, J

1. The appellant [Assessee] has filed the present appeals under Section 260A of the Income Tax Act, 1961 [the Act] impugning a common order dated 18.12.2024 passed by the Income Tax Appellate Tribunal [the Tribunal] in ITA Nos.2237/Del/2024 and 2238/Del/2024 captioned Tungsten Network Ltd. v. Deputy Commissioner of Income Tax in respect of the assessment years [AYs] 2016-17 and 2017-18.

2. The Assessee had preferred the said appeals before the Tribunal impugning separate assessment orders dated 12.03.2024 passed by the Assessing Officer [AO] under Section 147 read with Section 144 of the Act in respect of AYs 2016-17 and 2017-18. The final assessment orders were passed pursuant to directions issued by the Dispute Resolution Panel [DRP under Section 144 C(5) of the Act by separate orders dated 22.02.2024 passed in respect of each of the relevant AYs 2016-17 and 2017-18.

3. The Assessee is a company incorporated under the laws of the United Kingdom [UK] and is a tax resident of the UK. The Assessee is a wholly owned subsidiary of Tungsten Corporation Plc, which is also a company incorporated in the UK. The Assessee had not filed its return of income for the