M/S. RIBBON COMMUNICATION PRIVATE LIMITED (FORMERLY KNOWN AS SONUS NETWORKS INDIA PRIVATE LIMITED ),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(2), BANGALORE

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ITA 2971/BANG/2018Status: DisposedITAT Bangalore23 August 2023AY 2014-152 pages

In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The assessee requested to withdraw the appeal as the grounds raised before the Tribunal were consequential to the MAP resolution. The Tribunal allowed the withdrawal.

What were the facts?

The assessee filed an appeal before the ITAT against an assessment order. The principal transfer pricing issues had been resolved through Mutual Agreement Proceedings (MAP).

What were the issues?

Whether the appeal filed before the ITAT is maintainable when the core transfer pricing issues have been resolved through MAP.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH : BANGALORE

Before: SHRI GEORGE GEORGE K & SHRI LAXMI PRASAD SAHU

For Appellant: Smt. Rashmi R, Advocate
For Respondent: Shri. D. K. Mishra, CIT(DR)(ITAT), Bengaluru
Hearing: 23.08.2023Pronounced: 23.08.2023

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENT AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER IT(TP)A No.2971/Bang/2018 Assessment Year : 2014-15 M/s. Ribbon Communication Pvt. Ltd., Vs. DCIT, (formerly known as Sonus Networks India Circle – 6(1)(2), Private Limited), Bengaluru. Swarna Latha P V, 2nd Floor, Delta Block, Embassy Tech Square, Kadubeesenahalli Village, Outer Ring Road, Varthur Hobli, Bengaluru – 560 103. PAN : AALCS 5706 R APPELLANT RESPONDENT Assessee by : Smt. Rashmi R, Advocate Revenue by : Shri. D. K. Mishra, CIT(DR)(ITAT), Bengaluru Date of hearing : 23.08.2023 Date of Pronouncement : 23.08.2023 O R D E R Per George George K, Vice President :

This appeal at the instance of assessee is directed against the Assessment Order of DCIT (order dated 31.08.2023), passed under section 143(3) r.w.s. 144C(3) of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2014-15.

2.

When this appeal came up for hearing, the learned Counsel for assessee Smt. Rashmi R, Advocate, submitted that the principal grounds pertaining to transfer pricing are resolved under the Mutual Agreement Proceedings (MAP) and the grounds raised before the Tribunal are consequential in nature, and IT(TP)A No.2971/Bang/2018 Page 2 of 2 hence the assessee wants to withdraw the appeal filed before the Tribunal. Accordingly, the appeal is dismissed as withdrawn.

3.

In the result, appeal of the assessee is dismissed as withdrawn.

Pronounced in the open court on the date mentioned on the caption page.

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