DASSAULT SYSTEMS SA,FRANCE vs. ACIT (INTERNATIONAL TAXATION), CIRCLE-1(2)(2), NEW DELHI

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ITA 7702/DEL/2017Status: DisposedITAT Delhi30 June 2025AY 2013-14Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL, ACCOUNTANT MEMBER (Assessment Year: 2013-14) Dassault System SE Vs. The ACIT, Circle 1(2)(2) (earlier known as International Taxation, Dassault Systems SA) New Delhi 10, Rue Marcel Dassault, CS 40501, 78946 Velizy Villacoublay Cedex France स्थायीलेखासं . / जी आइआरसं . / PAN/GIR No: AADCD5443N Appellant Respondent Appellant by : Sh. Yishu Goel, CA Respondent by : Sh. Rajesh Kumar Dhanesta, Sr. DR. Date of Hearing 27.06.2025 Date of Pr1 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The Tribunal noted that the assessee had opted for the Vivad se Vishwas Scheme and accordingly dismissed the appeal as withdrawn. Liberty was granted to the assessee to seek recall of the order if unsuccessful in the scheme.

What were the facts?

The assessee, Dassault System SE, filed an appeal against an order for Assessment Year 2013-14. During the hearing, the assessee's counsel informed the tribunal that the assessee had opted for The Direct Tax Vivad se Vishwas Scheme, 2024.

What were the issues?

Whether the appeal should be dismissed as withdrawn due to the assessee opting for the Vivad se Vishwas Scheme.

Which sections of the Income-tax Act were involved?

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D” BENCH, DELHI

Before: SHRI MAHAVIR SINGH & SHRI MANISH AGARWAL

Hearing: 27.06.2025Pronounced: 27.06.2025

This appeal by the assessee is directed against the order of DRP-1, New Delhi dated 28.08.2017 for the assessment year 2013-14.

2.

When this appeal was called for hearing, learned Counsel for the assessee filed petition dated 20th May, 2025 stating that assessee has opted for The Direct Tax Vivad se Vishwas Scheme, 2024 for the relevant assessment year 2013-14. The assessee stated that it has filed Form No. 1 and the Revenue has also issued Form No.2, which are enclosed as Annexures in the petition.

3.

Since the assessee has opted for Vivad se Vishwas Scheme, we dismiss this appeal as withdrawn. However, we are granting liberty to the assessee that in case the assessee is not successful in getting through the Vivad se Vishwas Scheme, it is free to get this order recalled. In terms of the above, the appeal is dismissed as withdrawn.

4.

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

Decision pronounced in the open Court on conclusion of hearing on 27th June, 2025.

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