What did the Tribunal hold?

The Tribunal noted that the assessee has opted for settlement under the Vivad Se Vishwas Scheme and has paid the settlement amount. The Tribunal accordingly dismissed the appeal as withdrawn.

The assessee filed an appeal against the order of CIT(A) for the assessment year 2003-04. The assessee subsequently opted for settlement under the 'Vivad Se Vishwas Scheme-2024' and paid the settlement amount.

What were the issues?

Whether the appeal should be dismissed as withdrawn due to settlement under the Vivad Se Vishwas Scheme.

General Electric Company vs DDIT | ITAT Mumbai 2025

Income Tax Appellate Tribunal, ‘I’ BENCH

Before: SHRI AMIT SHUKLA & SHRI VIKRAM SINGH YADAV

For Appellant: Shri Mrunal Parekh

For Respondent: Shri Krishna Kumar, Sr. DR

Hearing: 06/03/2025Pronounced: 06/03/2025

आदेश / O R D E R PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the assessee against order passed by CIT(A)-10, Mumbai dated 20/07/2010 for the quantum of assessment passed u/s.143(3) for the A.Y.2003-04.

General Electric Company 2. In the aforesaid appeal, ld. Counsel for the assessee has submitted that assessee has opted for settlement of its tax dispute under the ‘Vivad Se Vishwas Scheme-2024’ and has also filed application vide letter dated 06/02/2025 before the authorities. For the sake of ready reference, the letter is reproduced hereunder:-

This is with reference to the captioned appeal filed before the Hon'ble Income Tax Appellate Tribunal (the Tribunal') on 11 October 2010. Acknowledgement copy of the appeal is enclosed as Annexure 1. In this regard, the Appellant submits that it has opted to settle the captioned appeal under the Direct Tax Vivad Se Vishwas Scheme, 2024 ('VsV Scheme') as follows:  The Appellant has filed Form 1 opting for the VsV Scheme on 30 December 2024-copy of Form 1 is enclosed as Annexure 2  Subsequently, the designated authority has issued a certificate in Form 2 dated 29 January 2025 with acknowledgement no. 849721281290125, confirming the acceptance of aforesaid Form 1 and determining INR 30,000 as payable by the Appellant towards full and final settlement of the captioned appeal under the VsV Scheme copy of Form 2 is enclosed as Annexure 3.  The Appellant has made the payment of said amount on 5 February 2025-copy of payment challan is enclosed as Annexure 4. Considering the above, the Appellant wishes to withdraw the captioned appeal filed before the Hon'ble Tribunal for AY 2003- 04. We hope your Honors will accede to our request. In case your Honors require any additional information, please do let us know and we shall be glad to provide the same.

Accordingly, appeal of the assessee is dismissed as withdrawn, however, liberty is given to the assessee in case the application for VSVS does not materialize and is not accepted, assessee may file an application for restoration of the appeal. Accordingly, appeal of the assessee is dismissed in limine.

3. In the result, appeal of the assessee is dismissed.

Order pronounced on 6th March, 2025.

GENERAL ELECTRIC COMPANY,MUMBAI vs. DDIT (IT) RG 3(1), MUMBAI

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