THE GOODYEAR TIRE & RUBBER COMPANY,FARIDABAD vs. DCIT, CIRCLE- GURGAON, INTERNATIONAL TAXATION, GURGAON

PER SAKTIJIT DEY : JM

These appeals by the Assessee for the assessment years

2007-08 to 2014-15 and 2016-17 are directed against the

respective separate orders of Ld. Assessing Officer as well as Ld.

CIT(A).

drawn our attention towards a request letter dated 29.9.2022

for withdrawal of appeals pursuant to resolution reached under

the Mutual Agreement Procedure (MAP) filed by the Evan M.

Scocos, Vice President and Controller of the assessee company,

which is available on record. He submitted that the assessee had

filed applications under MAP in accordance with Article 27 of the

India-US Double Taxation Avoidance Agreement (DTAA) and the

resolution has been reached by the US and Indian Competent

Authorities in terms of section 90 of the Act read with Article 27

of the DTAA. He further submitted that assesee is in agreement

with the resolution reached for the subject matter under appeal

and hence, would like to withdraw the appeals filed before the

Tribunal for the assessment years 2007-08 to 2014-15 and

2016-17 on the issues covered under MAP. In this regard, he

filed the communication dated 13.9.2022 for resolution of dispute

under MAP with the USA received from the Indian Competent

Authorities. He further submitted that in addition to above, the

assessee also wishes to withdraw its appeals in relation to the

other issues that are not covered under MAP with the income

tax authorities, with a view to end the disputes. In view of

above, Ld. AR has requested for withdrawal of assesse’s

appeals.

assessee.

allow the request of the assessee for withdrawal of the captioned

appeals and the same are dismissed as withdrawn.

Sd/- Sd/-

(G.S. PANNU) (SAKTIJIT DEY) PRESIDENT JUDICIAL MEMBER

SRB.