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Income Tax Appellate Tribunal, “A” BENCH : BANGALORE
Before: SMT. BEENA PILLAI & Ms. PADMAVATHY S
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dated 2.3.2023 which is reproduced below has submitted that all the grounds of appeal in IT(TP)A No.614/Bang/2020 is withdrawn for the reason that the resolution has been arrived at between Indian and US Competent Authorities in respect of the Transfer Pricing issues raised by the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Accordingly, the appeal is dismissed as withdrawn.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.