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Income Tax Appellate Tribunal, DELHI BENCH: ‘D’ NEW DELHI
Before: SHRI G.S. PANNU & SHRI SAKTIJIT DEY
Date of hearing 01.12.2022 Date of pronouncement 01.12.2022 ORDER
PER SAKTIJIT DEY, JUDICIAL MEMBER:
This is an appeal by the assessee against order dated 15.02.2019 of learned Commissioner of Income-Tax(Appeals)-43, New Delhi for the assessment year 2013-14. 2. We have heard Shri Akshay Uppal, learned counsel appearing for the assessee and Shri Gangadhar Panda, learned CIT-DR.
As could be seen from the order dated 26.08.2022, ground nos. 1 to 28 relating to the issue of existence of Permanent Establishment (PE) and taxability of business profits attributable to the PE, on assessee’s request, were dismissed as withdrawn in view of the fact that the issues were settled under Mutual Agreement Procedure (MAP).
As regards the only other surviving ground being ground no.29 relating to levy of interest under Section 234B of the Income-Tax Act, 1961, at the time of hearing, learned counsel appearing for the assessee submitted that while giving effect to MAP, the Assessing Officer has not charged any interest under Section 234B of the Act.
Therefore, on instructions, he sought permission to withdraw ground no.29, as well.
Considering the above, ground no.29 is dismissed as not pressed.
In the result, the appeal is dismissed as withdrawn.
Order pronounced in the open court on Ist December, 2022.