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Facts
The assessee, Brose India Automotive Systems Private Limited, filed an appeal against an assessment order for AY 2015-16. Subsequently, the assessee entered into an Advance Pricing Agreement (APA) with the CBDT, which covered the assessment year under appeal and the international transactions in dispute. Consequently, the assessee filed an application to withdraw the appeal before the Income Tax Appellate Tribunal.
Held
The Tribunal noted that the Ld. Departmental Representative had no objection to the withdrawal of the appeal. Considering the finalization of the APA agreement covering the disputed transactions, the Tribunal allowed the assessee's request and dismissed the appeal as 'Withdrawn'.
Key Issues
Whether an appeal filed by an assessee can be withdrawn by the Income Tax Appellate Tribunal following the finalization of an Advance Pricing Agreement (APA) with the CBDT, which covers the assessment year and the international transactions under dispute in the appeal.
Sections Cited
143(3), 144C(13)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, PUNE BENCHES “C”, PUNE
Before: DR.MANISH BORAD & SHRI VINAY BHAMORE
PER DR. MANISH BORAD, ACCOUNTANT MEMBER :
The captioned appeal at the instance of assessee pertaining to Assessment Year 2015-16 is directed against the order dated 19.10.2019 passed by Ld. Assessing Officer u/s.143(3) r.w.s.144C(13) of the Income Tax Act, 1961.
Before us, assessee has filed an application dated 15.09.2025 seeking withdrawal of the appeal. The relevant contents of the said application reads as under :
Ld. Departmental Representative has no objection for withdrawal of the appeal filed by the assessee. We therefore allow the request of the assessee to withdraw the appeal filed by it.
In the result, the appeal of the assessee is dismissed as ‘Withdrawn’.
Order pronounced at the time of hearing itself, i.e. on 13th October, 2025.