SOFTWARE AG BANGALORE TECHNOLOGIES PRIVATE LIMITED,BANGALORE, KARNATAKA vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-6(1)(2), BANGALORE, BANGALORE, KARNATAKA

These are the appeals filed by the assessee against the order passed by the NFAC, Delhi dated 13/03/2024 and 23/03/2024 for the assessment years 2014-15 and 2017-18.

In the present appeals, the assessee has contended that it intends to settle the dispute under Vivad Se Vishwas (VSV) Scheme 2024 introduced by the Government of India. Accordingly, during the course of the proceedings before us, the ld. Authorized Representative (AR) of the assessee submitted that the assessee is in the process of settling the tax dispute in the appeal on hand and filed Form-2/4 as prescribed under the Direct Tax Vivad se Vishwas Scheme (DTVSV), 2024, issued by the Competent Authority in support of its contention. Accordingly, the ld. AR filed the letters dated 21-01-2025 and 23-01-2025 requesting for the withdrawal of appeals.

The Learned Departmental Representative (DR) confirmed the submission of the AR and raised no objection to the dismissal of the appeals in light of the settlement of dispute under DTVSV, 2024.

Considering the submission of the parties and in view of the fact that Form-2/4 has been issued by the revenue authority, we find that no purpose would be served by keeping this appeal pending before the Tribunal. Accordingly, these appeals are dismissed as the issue is being resolved under the Direct Tax Vivad se Vishwas Scheme, 2024. However, before parting it is clarified that in the event the Competent Authority under DTVSV, 2024, for any reason, deems the settlement to be non- operative or invalid, the assessee shall be at liberty to approach the Tribunal by filing a suitable application for restoration of the appeal to its original number as per the provisions of law.