MICROSOFT GLOBAL SERVICES CENTRE INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD
Income Tax Appellate Tribunal, HYDERABAD “A” BENCH: HYDERABAD
Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G
PER VIJAY PAL RAO, V.P. :
This appeal filed by the Assessee has been directed against the Final
Assessment
Order dated
25.07.2024 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 06.06.2024 of the Disputes Resolution Panel-1, [in short “DRP”], Bengaluru,
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passed u/sec.144C(5) of the Act, for the assessment year
2020-2021. 2. At the time of hearing, Learned Authorised
Representative for the Assessee 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CIT-DR for the Revenue, on the other hand, has no objection if the present appeal of the assessee is dismissed as withdrawn.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 appeal has been resolved by the 3
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Competent Authorities of India and US as communicated by the CBDT vide letter dated 11.09.2025 as under :
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In view of the fact that the dispute involved in the present appeal of the assessee has already been resolved in the MAP proceedings, accordingly, the assessee is allowed to withdraw the present appeal and consequently, the appeal of the assessee is dismissed as withdrawn.
In the result, appeal of the Assessee dismissed as withdrawn.
Order pronounced on conclusion of hearing in the open Court on 23.09.2025. [MANJUNATHA G.]
[VIJAYPAL RAO]
ACCOUNTANT MEMBER VICE PRESIDENT
Hyderabad, Dated 23rd September, 2025
VBP
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Copy to 1. Microsoft Global Services Centre India Private Limited,
Building-1, Microsoft Campus, Gachibowli, Hyderabad.
PIN – 500 032. Telangana.
2. The DCIT, Circle-5(1), IT Towers, Hyderabad – 500 004
Telangana.
The Disputes Resolution Panel-1, 4th Floor, Kendriya Sadan, C-Wing, BENGALURU – 560 034. Karnataka. 4. The Pr. CIT, Hyderabad. 5. The Addl./Joint Commissioner of Income Tax, Transfer Pricing Officer, Aaykar Bhawan, Opp. LB Stadium, Basheerbagh, Hyderabad – 500 004. Telangana. 6. The DR ITAT “A” Bench, Hyderabad. 7. Guard File.
//By Order//
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