3M INDIA LIMITED,BANGALORE vs. DCIT, LTU, BANGALORE

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ITTPA 311/BANG/2014Status: DisposedITAT Bangalore17 October 2025AY 2009-102 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The Tribunal dismissed the appeal filed by 3M India Limited for the assessment year 2009-10 as withdrawn. This decision was based on the assessee's letter dated 13.10.2025, requesting withdrawal due to the settlement of the disputed issues under the Direct Tax Vivad Se Vishwas Scheme, 2024. The settlement was supported by Form 1 dated 30.4.2025 and Form 2 dated 09.10.2025 issued by the Principal Commissioner of Income Tax, Bengaluru-2. The assessee's authorized representative reiterated this request, and the Department's representative agreed. Consequently, the Tribunal found no impediment to allowing the withdrawal and dismissing the appeal. No specific issue was decided on merits; the operative direction was to dismiss the appeal as withdrawn.

What were the facts?

The assessee, 3M India Limited, filed an appeal for assessment year 2009-10 against the order of the CIT(Appeals), LTU, Bangalore, which had partly allowed the assessee's appeal against the final assessment order passed by the DCIT, LTU, Bangalore under section 143(3) r.w.s. 144C(13) of the Income-tax Act, 1961. The assessee subsequently filed a letter requesting withdrawal of the appeal, citing settlement of the disputed issues under the Direct Tax Vivad Se Vishwas Scheme, 2024. This was evidenced by Form 1 dated 30.4.2025 and Form 2 dated 09.10.2025 issued by the PCIT, Bengaluru-2. The assessee's authorized representative reiterated this request, and the Department's representative agreed.

What were the issues?

1. Whether the appeal filed by the assessee for assessment year 2009-10 should be dismissed as withdrawn in light of the settlement under the Direct Tax Vivad Se Vishwas Scheme, 2024, as per the assessee's request and the revenue's agreement. Assessee's contention: The assessee contended that the appeal should be withdrawn as the disputed issues have been settled under the Direct Tax Vivad Se Vishwas Scheme, 2024, providing Form 1 and Form 2 as evidence. The assessee requested the dismissal of the appeal as withdrawn. Revenue's contention: The revenue agreed to the assessee's request for withdrawal of the appeal.

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, “C” BENCH : BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

For Respondent: Shri Shruti Agarwal, AR, Shri Aseem Sharma, CIT(DR)(ITAT), Bengaluru
Hearing: 16.10.2025Pronounced: 17.10.2025

Per Prashant Maharishi, Vice President 1. This appeal is filed by 3M India Limited (the assessee/appellant) for the assessment year 2009-10 against the appellate order passed by the CIT(Appeals), Large Taxpayers Unit [LTU], Bangalore [ld. CIT(A)] dated 31.01.2014 wherein the appeal filed by the assessee against the final assessment order u/s. 143(3) r.w.s. 144C(13) of the Income-tax Act, 1961 [the Act] passed by the DCIT, LTU, Bangalore, [ld. AO] dated 10.5.2013 was partly allowed.

IT(TP)A No.311/Bang/2014 Page 2 of 2

2.

The assessee has filed a letter dated 13.10.2025 requesting for withdrawal of the appeal in view of the settlement of the issue(s) in appeal under the Direct Tax Vivad Se Vishwas Scheme, 2024 [DTVSV] vide Form 1 dated 30.4.2025 and issuance of Form 2 dated 09.10.2025 by the ld. PCIT, Bengaluru-2, Bengaluru (copies of Form 1 & Form 2 filed on record). The ld. AR reiterated the same and requested for withdrawal of the appeal, to which the ld. DR agreed.

3.

In view of the above facts, we dismiss the appeal of the assessee as withdrawn.

Pronounced in the open court on this 17th day of October, 2025.

Sd/- Sd/-

( KESHAV DUBEY ) ( PRASHANT MAHARISHI ) JUDICIAL MEMBER VICE PRESIDENT

Bangalore, Dated, the 17th October, 2025. /Desai S Murthy / Copy to: 1. Appellant 2. Respondent 3. Pr. CIT 4. CIT(A) 5. DR, ITAT, Bangalore. By order

Assistant Registrar ITAT, Bangalore.

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