These are 2 appeals filed by the assessee for assessment year 2004 – 05 and 2005 – 06 against the order of the ld CIT (A)-44, New Delhi dated 26.12.2017 for the AY 2004-05 and dated 31st of January 2018 for assessment year 2005 – 06. Most of the grounds are common in both these appeals, therefore, they were argued together by the parties and disposed of by this common order.

That on the facts and circumstances of the case and in law, the order dated December 26, 2017, passed by the Ld. CIT(A) under Section 250 of the Act, to the extent the additions made by the Ld. AO in the assessment order under Section 143(3) are sustained, is erroneous and bad in law and is liable to be set aside

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