DASSAULT SYSTEMES SE,10, RUE MARCEL DASSAULT, CS 40501, 78946 VELIZY VILLACOUBLAY CEDEX, FRANCE vs. ACIT CIRCLE 1(2)(2) INTERNATIONAL TAXATION, NEW DELHI

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ITA 1898/DEL/2023Status: DisposedITAT Delhi23 May 2025AY 2020-21Bench: SHRI MAHAVIR SINGH, HON’BLE (Vice President), SHRI AVDHESH KUMAR MISHRA (Accountant Member)4 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 has opted to settle the disputed issues under the Vivad se Vishwas Scheme, 2024 and allowed the withdrawal of appeals with liberty to revive.

What were the facts?

The assessee filed applications to withdraw these appeals for AY 2014-15, 2020-21, and 2021-22, stating they have opted to settle disputed issues under the Vivad se Vishwas Scheme, 2024.

What were the issues?

Whether the assessee can withdraw appeals filed before the tribunal to settle disputes under Vivad se Vishwas Scheme, 2024.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘D’: NEW DELHI

Before: SHRI MAHAVIR SINGH, HON’BLE & SHRI AVDHESH KUMAR MISHRA

For Respondent: Shri Dheeraj Kumar Jain, Sr. DR
Hearing: 23/05/2025Pronounced: 23/05/2025

Heard together (3 matters)

ITA No.6119/DEL/2018
ITA No.1898/DEL/2023
ITA No.3238 /DEL/2023

Read from the judgment's own cause title. This page is filed under one of them.

1.

These appeals filed by the assessee are directed against the orders, dated 18.06.2018, 28.04.2023 and 22.09.2023, passed under section 143(3) r.w.s.144C(13) of the Income Tax Act, 1961 by the Assistant Commissioner of Income Tax, Circle- 1(2)(2), International Taxation, New Delhi.

2.

The assessee has filed applications for the above-mentioned appeals; 1898/DEL/2023 and 3238/DEL/2023 dated 14.05.2025 for withdrawal of these appeals for AY 2014-15, 2020-21 and 2021-22 on the reasoning that it has opted to settle the disputed issues for these years under the Vivad se Vishwas Scheme, 2024. The assessee has placed on record copies of Form No. 2 filed under VSVS, 2024. The Ld. Authorized Representative for assessee prayed for liberty to revive appeals in case any of the applications of the assessee fails to mature for any reason under Vivad se Vishwas Scheme, 2024.

3.

The Ld. Sr. DR raised no objection to withdrawal of these appeals by the assessee.

4.

Heard. In view of the above-mentioned applications of the assessee, the above captioned appeals of the assessee for AY 2014-15, 2020-21 and 2021-22 are dismissed as withdrawn as the assessee has opted to settle the disputed issues of these years under Vivad se Vishwas Scheme. Liberty is granted to the assessee to revive the appeal if any of its application under Vivad se Vishwas Scheme, 2024 fails to mature.

5.

In view of the above, these appeals of the assessee stand dismissed as withdrawn.

Order pronounced in open Court on 23rd May, 2025

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