Loading judgment…
Facts
The assessee filed an appeal against the assessment order for AY 2020-21. During the hearing, the assessee's AR submitted that a MAP resolution had been agreed upon by the Competent Authorities of India and USA for the said AY.
Held
The Tribunal noted that the issues in appeal were resolved under the MAP. Consequently, the assessee sought withdrawal of the appeal. The appeal was accordingly dismissed as withdrawn.
Key Issues
Whether the appeal could be dismissed as withdrawn due to a MAP resolution resolving the dispute.
Sections Cited
143(3), 144C(13)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “C” BENCH : BANGALORE
Before: SHRI PRASHANT MAHARISHI & SHRI SOUNDARARAJAN K.
Per Prashant Maharishi, Vice President
This appeal is filed by XLHealth Corporation India Pvt. Ltd., now Amalgamated with Optum Global Solutions (India) Pvt. Ltd., (the assessee/appellant) for the assessment year 2020-21 against the assessment order passed u/s. 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 [the Act] by the Assessment Unit of the Income Tax Department [ld. AO] dated 18.6.2024.
During the course of hearing, the ld. AR submitted that the appellant has received a MAP resolution agreed upon by the Competent Authorities of India and USA for AY 2020-21 dated 18.9.2025 (copy placed on record) and thus the issues in appeal have been resolved under the MAP and hence withdrawal of the appeal was sought for. In this regard, the letter dated 23.9.2025 of the appellant is filed on record. Accordingly, after hearing both the parties, the appeal of the assessee is dismissed as withdrawn.
Pronounced in the open court on this 19th day of November, 2025.