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M/S NTT DATA GLOBL DELIVERY SERVICES LTD ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-5(1)(1), BANGALORE

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ITA 2842/BANG/2017[2005-06]Status: DisposedITAT Bangalore26 June 20256 pages

Income Tax Appellate Tribunal, “C” BENCH : BANGALORE

For Appellant: Shri. Keerthi Narayan, CA
For Respondent: Shri. Dilip, Junior Standing Counsel.
Hearing: 23.06.2025Pronounced: 26.06.2025

Per Laxmi Prasad Sahu, Accountant Member : This appeal filed by the assessee against the final assessment order passed by the AO, dated 23/10/2017 for making addition of Rs.2,96,12,568/- as per adjustment suggested by the Transfer Pricing Officer (TPO) vide Order dated 30.11.2016 passed under section 254 r.w.s. 92CA of the Act. 2. At the outset of hearing, the learned Counsel submitted that the assessee was providing back support services to its group entities and he issue raised by the AO/TPO has been resolved under Mutual Agreement Proceedure (MAP) under article 27 of the India-US Double Tax Avoidance Agreement and further

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submitted that as per MAP resolution by both the competent authorities of MAP, assessee has got relief as under:

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3. The assessee has filed a letter dated 04.06.2025 and a per letter it seeking withdrawal of the appeal :

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4. Learned DR has no objection for withdrawing the appeal. On going through the application filed by the assessee before the Bench on 23.06.2025, we noted that the dispute raised by the AO/TPO has been resolved under MAP as noted above. Accordingly, we accept the application filed by the assessee which is placed on record.
5. In result, the appeal of the assessee is dismissed as withdrawn.
Pronounced in the court on the date mentioned on the caption page. (SOUNDARARAJAN K)
Accountant Member
Bangalore,
Dated : 30.06.2025. /NS/*

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Copy to:
1. Appellant 2. Respondent 3. Pr.CIT4.CIT(A)
5. DR, ITAT, Bangalore.
By order

M/S NTT DATA GLOBL DELIVERY SERVICES LTD ,BANGALORE vs ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-5(1)(1), BANGALORE | BharatTax