M/S. TARGET CORPORATION INDIA PRIVATE LIMITED,BENGALURU vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BENGALURU

The assessee vide letter dated 2.3.2023 which is reproduced below has submitted that all the grounds of appeal in IT(TP)A No.614/Bang/2020 is withdrawn for the reason that the resolution has been arrived at between Indian and US Competent Authorities in respect of the Transfer Pricing issues raised by the assessee before the Tribunal:-

For easy of reference , copy of MAP resolution is reproduced below:-

Accordingly, the appeal is dismissed as withdrawn.

The appeal by the department is with regard to CIT(Appeals) holding certain expenses to be part of operating cost of the assessee for the purpose of TP adjustment. Since the MAP resolution entered into with competent authorities covers the TP adjustment as reproduced above, the appeal of the revenue has become infructuous and accordingly dismissed.

In the result, both the appeals by the assessee and the revenue are dismissed.