MICROSOFT GLOBAL SERVICES CENTER INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE 5(1), HYDERABAD
Income Tax Appellate Tribunal, Hyderabad ‘ A ‘ Bench, Hyderabad
PER MANJUNATHA G., A.M :
This appeal filed by the assessee company has been directed against the Final Assessment Order dated 29.10.2024
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Microsoft Global Services Center India Private Ltd.
passed u/sec.143(3) r.w.s.144C(13) r.w.s.144B of the Income Tax
Act, 1961 [in short “the Act”] in pursuance to the Directions dated
17.09.2024 of the Disputes Resolution Panel-1, [in short “DRP”],
Bengaluru, passed u/sec.144C(5) of the Act, for the assessment year 2021-22. 2. At the time of hearing, Learned Authorised Representative for the assessee company Shri Parth, Advocate, has submitted that the dispute involved in this appeal has been resolved under the MAP as per the Order of the communication of the CBDT dated 11.09.2025 and copy of the same is filed before the Tribunal. Thus, the learned Authorised Representative for the Assessee submitted that the assessee may be allowed to withdraw the present appeal as the dispute has been settled under MAP.
3. The Learned CIT-DR for the Revenue Ms. U. Mini Chandran,
Ld.CIT-DR, on the other hand, has no objection if the present appeal of the assessee is dismissed as withdrawn.
4. Considering the submissions of the learned Authorised
Representative for the Assessee and the learned CIT-DR for the Revenue, at the outset, we note that the dispute involved in this 3
Microsoft Global Services Center India Private Ltd.
appeal has been resolved by the Competent Authorities of India and US as communicated by the CBDT vide letter dated
11.09.2025 as under :
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Microsoft Global Services Center India Private Ltd.
In view of the fact that the dispute involved in the present appeal of the assessee company has already been resolved in the MAP proceedings, accordingly, the assessee company is allowed to withdraw the present appeal and consequently, the appeal of the assessee company is dismissed as withdrawn.
In the result, appeal of the assessee company is dismissed as withdrawn.
Order pronounced in the Open Court on 6th October, 2025. (श्री रवीश सूद)
(RAVISH SOOD)
न्यायिक सदस्य/JUDICIAL MEMBER (मंजूिधथ जी)
(MANJUNATHA G.)
लेखा सदस्य/ACCOUNTANT MEMBER
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Microsoft Global Services Center India Private Ltd.
Hyderabad, dated 06.10.2025. TYNM/sps
आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:-
निर्धाररती/The Assessee : Microsoft Global Services Centre India Private Limited, Building-1, Microsoft Campus, Gachibowli, Hyderabad. PIN – 500 032. Telangana. 2. रधजस्व/ The Revenue : The DCIT, Circle-5(1), IT Towers, Hyderabad – 500 004, Telangana. 3. The Principal Commissioner of Income Tax, Hyderabad. 4. The Disputes Resolution Panel-1, 4th Floor, Kendriya Sadan, C-Wing, BENGALURU – 560 034. Karnataka. 5. The Addl./Joint Commissioner of Income Tax, Transfer Pricing Officer, Aaykar Bhawan, Opp. LB Stadium, Basheerbagh, Hyderabad – 500 004. Telangana. 6. नवभधगीयप्रनतनिनर्, आयकर अपीलीय अनर्करण, हैदरधबधद / DR, ITAT, Hyderabad 7. गधर्ाफ़धईल / Guard file
आदेशधिुसधर / BY ORDER
Sr. Private Secretary
ITAT, Hyderabad