CRRC ZHUZHOU LOCOMOTIVE CO LTD ,MUMBAI vs. ACIT INTERNATIONAL TAXATION CIRCLE 2(1)(1), MUMBAI
In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal allowed the assessee's request to withdraw the appeals, noting that the respondent did not raise any objection. Consequently, the appeals were dismissed as withdrawn.
What were the facts?
The assessee filed two appeals against the orders of the Assessing Officer for Assessment Years 2018-19 and 2019-20. The assessee sought permission to withdraw these appeals as they had opted to avail the Vivad Se Viswas Scheme.
What were the issues?
Whether the assessee can withdraw appeals after opting for the Vivad Se Viswas Scheme and if the appeals should be dismissed as withdrawn.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, MUMBAI “I” BENCH : MUMBAI
Before: SHRI SAKTIJIT DEY & SHRI VIKRAM SINGH YADAV
O R D E R PER VIKRAM SINGH YADAV, A.M : These are two appeals filed by the assessee against the order of the Assessing Officer (AO), consequent to the directions given by the CIT (DRP-1)-Mumbai-2, pertaining to Assessment Years (AYs) 2018-19 and 2019-20.
The Ld.AR submitted that the assessee company seeks permission to withdraw these appeals as the assessee-company has opted to avail Vivad Se Viswas Scheme, 2024 (VsV Scheme). In this connection, it was submitted that the assessee-company filed a petition for withdrawal of these appeals, wherein the assessee-company has requested the Bench for permission to withdraw these appeals and the contents of the petition read as under: “The captioned appeals are fixed for hearing before the 'I' Bench of the Hon'ble Income-tax Appellate Tribunal, Mumbai on 24 June 2025. In this regard, we respectfully submit that the Appellant has opted to settle the disputes under "The Direct Tax Vivad se Vishwas Scheme, 2024' ('VsV Scheme'), and the Designated Authority has issued Form No. 4, confirming the full and final settlement of the tax arrears. A copy of Form No. 4 is enclosed herewith as Annexure-1 for your reference. Accordingly, we request that an early hearing be granted to facilitate the formal withdrawal of the aforementioned appeals, as they have been rendered infructuous in light of the settlement under the VSV Scheme. We pray to your Honours to kindly accede to our request and oblige. Thanking You. Yours faithfully, For CRRC Zhuzhou Locomotive Company Limited”
The Ld. DR didn’t raise any specific objection to such request for withdrawals of the subject appeals.
Having heard both the parties and taking into consideration the petition so filed, we are inclined to allow these appeals of the assessee to be withdrawn yielding to the prayer of the Ld.AR and accordingly, dismiss these appeals as withdrawn.
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