JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-7, BANGALORE vs. M/S. TARGET CORPORATION INDIA PRIVATE LIMITED, BANGALORE
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Income Tax Appellate Tribunal, “A” BENCH : BANGALORE
Before: SMT. BEENA PILLAI & Ms. PADMAVATHY S
IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND Ms. PADMAVATHY S, ACCOUNTANT MEMBER
IT(TP)A No.614/Bang/2020 Assessment year : 2015-16
M/s. Target Corporation India Pvt. Ltd., Vs. The Joint Commissioner of C2 Block, Embassy Manyata Business Park, Income Tax, Nagawara Hobli, Special Range-7, Outer Ring Road, Bengaluru. Bengaluru – 560 045. PAN: AAECA 8990N APPELLANT RESPONDENT
IT(TP)A No.657Bang/2020 Assessment year : 2015-16
The Joint Commissioner Vs. M/s. Target Corporation India Pvt. Ltd., of Income Tax, Bengaluru – 560 045. PAN: AAECA 8990N Special Range-7, Bengaluru. APPELLANT RESPONDENT
Assessee by : Shri Ankur Pai, Advocate Revenue by : Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru.
Date of hearing : 30.03.2023 Date of Pronouncement : 30.03.2023
IT(TP)A No.614 & 657/Bang/2020 Page 2 of 7
O R D E R Per Bench These appeals of the assessee and the revenue are against the order of the CIT(Appeals)-10, Bengaluru dated 28.2.2020 for assessment year 2015-16.
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dated 2.3.2023 which is reproduced below has submitted that all the grounds of appeal in IT(TP)A No.614/Bang/2020 is withdrawn for the reason that the resolution has been arrived at between Indian and US Competent Authorities in respect of the Transfer Pricing issues raised by the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:-
IT(TP)A No.614 & 657/Bang/2020 Page 3 of 7
IT(TP)A No.614 & 657/Bang/2020 Page 4 of 7
For easy of reference , copy of MAP resolution is reproduced below:-
IT(TP)A No.614 & 657/Bang/2020 Page 5 of 7
IT(TP)A No.614 & 657/Bang/2020 Page 6 of 7
Accordingly, the appeal is dismissed as withdrawn.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.
IT(TP)A No.614 & 657/Bang/2020 Page 7 of 7
In the result, both the appeals by the assessee and the revenue are dismissed.
Pronounced in the open court on this 30th day of March, 2023. Sd/- Sd/- ( BEENA PILLAI ) ( PADMAVATHY S. ) JUDICIAL MEMBER ACCOUNTANT MEMBER
Bangalore, Dated, the 30th March, 2023.
/Desai S Murthy /
Copy to:
Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR, ITAT, Bangalore.
By order
Assistant Registrar ITAT, Bangalore.
