ORDER

PER S.RIFAUR RAHMAN,AM:

1. The assessee, SMS Siemag AG, and the Revenue has filed cross appeals against the order of ld. Commissioner of Income-tax (Appeals)-XXIX, New Delhi (hereinafter referred to ‘Ld. CIT (A)’) dated 02.01.2014 for Assessment Year 2005-06.

2. The assessee, SMS Concast AG, has filed four appeals against the separate orders of ld. Commissioner of Income-tax (Appeals)-43, New Delhi (hereinafter referred to ‘Ld. CIT (A)’) dated 31.01.2018, 16.01.2019, 21.04.2022 & 21.04.2022 for Assessment Year 2014-15, 2015-16, 2016-17 & 2017-18 respectively.

3. Since the issues are common and the appeals are connected, hence the same are heard together and being disposed off by this common order. We take up the assessee’s appeal being ITA No.1073/Del/2014 for AY 2005-06 as lead case to adjudicate the issues under consideration.

4. The relevant facts of the case are, assessee filed its return of income on 29.11.2006 declaring income at Rs.8,11,98,063/-. The return was processed under section 143(1) of the Income-tax Act, 1961 (for short ‘the Act’) on returned income. Subsequently, the case was selected for reassessment and notices u/s 148 of the Act was issued and served on the as