M/S. REDINGTON DISTRIBUTION PTE. LTD.,SINGAPORE vs. ACIT, INTL TAXATION CIRCLE-2(1), CHENNAI
In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal allowed the appeals of the assessee to be withdrawn. The decision was based on the assessee's submission that the disputes, which were the subject matter of these appeals for AYs 2019-20 and 2022-23, had been resolved through the Mutual Agreement Procedure (MAP) under Article 27 of the India-Singapore DTAA. This resolution was confirmed by a communication dated 06.02.2026. The assessee had filed a letter dated 11.02.2026 expressing its desire to withdraw the appeals in light of this resolution, in accordance with Rule 44G(8) of the Income-tax Rules, 1962. The revenue did not object to this request. Therefore, the Tribunal, considering the resolution of the dispute and the assessee's request, permitted the withdrawal of the appeals.
What were the facts?
These appeals by the assessee, M/s. Redington Distribution Pte Ltd., are against final assessment orders for Assessment Years (AY) 2019-20 and 2022-23. The orders were passed by the Assistant Commissioner of Income Tax, International Taxation Circle-2(1), Chennai, under Section 147 read with Section 144C(13) of the Income Tax Act, 1961, pursuant to directions from the Dispute Resolution Panel (DRP), Bangalore. The DRP's directions for AY 2019-20 were dated 28.12.2024, and for AY 2022-23, they were dated 27.12.2024. The assessee informed the Tribunal that issues involved in these appeals were resolved through a Mutual Agreement Procedure (MAP) under Article 27 of the India-Singapore Double Taxation Avoidance Agreement (DTAA). A communication dated 06.02.2026 confirmed the resolution of the dispute.
What were the issues?
1. Whether the assessee's appeals for AYs 2019-20 and 2022-23 can be withdrawn in light of the resolution of disputes under the Mutual Agreement Procedure (MAP) under Article 27 of the India-Singapore DTAA, as per Rule 44G(8) of the Income-tax Rules, 1962. Assessee's contention: The assessee argued that the issues involved in these appeals have been resolved through the MAP between the Competent Authorities of India and Singapore, as confirmed by a communication dated 06.02.2026. Consequently, the assessee desires not to litigate further and seeks to withdraw these appeals, providing acceptance and proof of withdrawal as required by Rule 44G(8) of the Income-tax Rules, 1962. Revenue's contention: The Revenue did not oppose the assessee's prayer for withdrawing the appeals.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI
Before: SHRI ABY T. VARKEY & MS. PADMAVATHY. S
आदेश / O R D E R PER ABY T. VARKEY, JM:
These appeals preferred by the assessee are against the final
assessment order dated 16.01.2025 for AY 2019-20 passed by the
Assistant Commissioner of Income Tax, International Taxation Circle-2(1),
Chennai, u/s.147 r.w.s.144C(13) of the Income Tax Act, 1961
(hereinafter referred to as ‘the Act‘) pursuant to the directions issued by
the Dispute Resolution Panel (hereinafter referred to as ‘DRP‘), Bangalore,
dated 28.12.2024 u/s.143(3) r.w.s.144C(1) of the Act; and (2) against
the final assessment order dated 15.01.2025 for AY 2022-23 passed by
IT (TP) A Nos.8 & 9/Chny/2025 (AYs 2019-20 & 2022-23) M/s. Redington Distribution Pte Ltd :: 2 ::
the ACIT, International Taxation Circle-2(1), Chennai, u/s.143(3)
r.w.s.144C(13) of the Act pursuant to the directions issued by the DRP,
Bangalore, dated 27.12.2024 u/s.143(3) r.w.s.144C(1) of the Act.
At the outset, the Ld.AR of the assessee brought to our notice that
pursuant to its application with the Inland Revenue Authority of Singapore
(Competent Authority ('CA') for Singapore) for a Mutual Agreement
Procedure (MAP) under Article 27 of the India - Singapore DTAA (on
issues involved in these appeals) were negotiated between the CAs of
India & Singapore and the same are resolved (refer communication of
resolution of dispute under MAP, letter F.No. 480/03/2018-SO/FT&TR-
II(2)/10 Dt. 06.02.2026). In the light of the ibid communication, the
assessee agrees to the resolution; and consequently, for settling the
dispute, desires not to litigate further before this Tribunal these captioned
appeals. Hence, as per Rule 44G(8) of the Income-tax Rules, 1962,
(hereinafter referred to as ‘the Rules‘) the assessee is required to provide
its acceptance along with the proof of withdrawal of the appeal pending
on the issues that were the subject matter of the resolution under MAP.
Accordingly, the assessee conveys its desire to withdraw these appeal
filed before this Tribunal for the captioned AYs 2019-20 & 2022-23 by
filing letter dated 11.02.2026.
IT (TP) A Nos.8 & 9/Chny/2025 (AYs 2019-20 & 2022-23) M/s. Redington Distribution Pte Ltd :: 3 ::
The Ld.DR doesn’t oppose the prayer of the assessee for
withdrawing their captioned appeals.
In the light of the aforesaid submission, considering the contents of
the letter dated 11.02.2026 as well as the communication of resolution
dispute under MAP in the case of the assessee for AYs 2019-20 & 2022-23 dated 06th February 2026, we allow the appeals of the assessee to be
withdrawn.
In the result, appeals filed by the assessee are allowed to be
withdrawn.
Order pronounced on the 04th day of March, 2026, in Chennai. Sd/- Sd/- (प�ावती .एस) (एबी टी. वक�) (PADMAVATHY. S) (ABY T. VARKEY) लेखा सद�य/ACCOUNTANT MEMBER �याियक सद�य/JUDICIAL MEMBER चे�ई/Chennai, �दनांक/Dated: 04th March, 2026. TLN आदेश क� �ितिलिप अ�ेिषत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF
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