FICOSA AUTOMOTIVE S L,OUTSIDE INDIA vs. ADIT (INTERNATIONAL TAXATION) - 1, HYDERABAD

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ITA 1356/HYD/2024Status: DisposedITAT Hyderabad16 June 2025AY 2021-22Bench: Shri Vijay Pal Rao (Vice President), Shri Manjunatha, G. (Accountant Member)6 pages

In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The assessee sought to withdraw the appeal, stating that the rectification order addressed their concerns. The Revenue did not object. The Tribunal allowed the withdrawal.

What were the facts?

The assessee filed an appeal against the assessment order. During the hearing, the assessee's AR submitted that the grievance has been redressed by the Assessing Officer's rectification order u/s 154 of the Act.

What were the issues?

Whether the appeal is to be dismissed as withdrawn after the assessee's grievance was redressed by a subsequent rectification order.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144C(5),Section 9(1)(vii),Section 56(2)(x)(a),Section 274,Section 270A,Section 154

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘ DB-A ‘ Bench, Hyderabad

Before: Shri Vijay Pal Rao, Vice-Shri Manjunatha, G.

Hearing: 16/06/2025

(िनधा�रण वष�/Assessment Year: 2021-22) Ficosa Automotive S L Vs. ADIT (International Outside India Taxation)-1 Hyderabad Hyderabad PAN:AAECF0477H (Appellant) (Respondent) िनधा��रती �ारा/Assessee by: C.A. Bhargavi, राज� व �ारा/Revenue by:: Shri B Bala Krishna, CIT(DR) सुनवाई की तारीख/Date of hearing: 16/06/2025 घोषणा की तारीख/Pronouncement: 16/06/2025 आदेश/ORDER Per Vijay Pal Rao, Vice President

This appeal filed by the assessee is directed against the order dated, 29/10/2024 passed u/s 143(3) r.w.s. 144C(13) of the I.T. Act, 1961, in pursuant to the directions of the DRP dated 28/09/2024 passed u/s 144C(5) of the Act for the A.Y 2021-22.

2.

The assessee has raised the following grounds of appeal:

3.

At the time of hearing, the learned AR of the assessee has filed an application and submitted that the grievance of assessee raised in the present appeal has been reddressed by the Assessing Officer while passing the order u/s 154 of the Act,

Page 2 of 4 dated 29/04/2025. A copy of the same is annexed to the said application. Thus, the learned AR has submitted that in view of the rectification order passed by the Assessing Officer u/s 154 of the Act, the assessee does not want to pursue the present appeal and seek leave of the Bench to withdraw the present appeal.

4.

On the other hand, the learned DR has raised no objection, if the appeal of the assessee is dismissed as withdrawn.

5.

Accordingly, in view of the application of the assessee as well as the order passed by the Assessing Officer u/s 154 of the Act, dated 29/04/2025, we allow the assessee to withdraw the present appeal and consequently, the appeal of the assessee is dismissed being withdrawn.

6.

In the result, appeal filed by the assessee is dismissed being withdrawn.

Order pronounced in the Open Court on the conclusion of hearing itself i.e. on 16th June, 2025.

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