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Facts
Five appeals filed by three Sandvik entities for Assessment Years 2017-18, 2019-20, and 2020-21, arising from orders under Section 143(3) read with Section 144C(13), were heard together. The assessees informed the Tribunal that they had opted for the Direct Tax Vivad se Vishwas Scheme, 2024, and requested to withdraw all their appeals.
Held
The Tribunal noted that the assessees had received Form 2 under the Vivad se Vishwas Scheme, 2024, and had sought withdrawal of their appeals as per Section 91(3) of the Finance (No. 2) Act, 2024. With no objection from the Departmental Representative, the Tribunal permitted the withdrawal, and all five appeals were dismissed as withdrawn.
Key Issues
Whether appeals should be allowed to be withdrawn by assessees who have opted for settlement under the Direct Tax Vivad se Vishwas Scheme, 2024.
Sections Cited
143(3), 144C(13), 91(3) of Finance (No. 2) Act, 2024
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, PUNE BENCHES “C” :: PUNE
Before: DR.DIPAK P. RIPOTE & SHRI VINAY BHAMORE
Assessment Year: 2020-21 Sandvik IT Services AB V The Assistant (Formerly known as AB s Commissioner of Income Sandvik Information Systems), Tax(international C/o.Sandvik Coromant India Taxation), Circle-2, Private Limited, Pune. Mumbai Pune Road, Dapodi, Pune – 411012. Maharashtra. PAN: AADCA5375J Appellant/ Assessee Respondent / Revenue आयकर अपील सं. / िनधा�रण वष� / Assessment Year: 2020-21 Sandvik AB, V The Assistant C/o.Sandvik Coromant India s Commissioner of Income Private Limited, Tax(international Mumbai Pune Road, Dapodi, Taxation), Circle-2, Pune – 411012. Maharashtra. Pune. PAN: AAHCS7486E Appellant/ Assessee Respondent / Revenue Assessee by Shri Yash Inamdar – AR Revenue by Shri Prakash L Pathade – CIT(DR) Date of hearing 02/06/2025 Date of pronouncement 03/06/2025 आदेश/ ORDER PER BENCH : These Five Appeals filed by the assessees are directed against the separate orders of (IT) Circle-1, and (IT) Circle-2, u/s.143(3) rws 144C(13) Pune for the A.Y.2017-18 and A.Y.2019-20, A.Y.2020-21 respectively. All these five appeals were heard together and are being disposed off by this common order for the sake of convenience.
, 225, 255/PUN/2023 & 435, 627/PUN/2024 [A]
At the outset of hearing, ld.AR for the assessee submitted that they are in receipt of Form 2 under VSVS Scheme-2024, therefore, assessee intends to withdraw all these five appeals. Ld.AR filed written requests(five) for withdrawal are as under :
, 225, 255/PUN/2023 & 435, 627/PUN/2024 [A] , 225, 255/PUN/2023 & 435, 627/PUN/2024 [A] , 225, 255/PUN/2023 & 435, 627/PUN/2024 [A] , 225, 255/PUN/2023 & 435, 627/PUN/2024 [A]
On the other hand, the ld.Departmental Representative(ld.DR) of the Revenue did not object to the contention of the assessee and has no objection if the appeals of assessee are dismissed as withdrawn.
, 225, 255/PUN/2023 & 435, 627/PUN/2024 [A]
In view of the above, we permit to withdraw all five appeals of the assessees. Accordingly, grounds of appeal raised by the assessees in all the appeals are dismissed as withdrawn.
In the result, five appeals of the assessee are dismissed as withdrawn. Order pronounced in the open Court on 03 June, 2025.