DIVERSEY INDIA HYGIENE PVT. LTD.(DIVERSEY INDIA PVT. LTD. MERGED WITH SEALED AIR (INDIA) P.LTD. AND LATER SEALED AIR (INDIA) PVY. LTD'S NAME CHANGED TO DIVERSEY INDIA HYGIENE P. LTD.),MUMBAI vs. DCIT, CIRCLE 11(2)(1), MUMBAI

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ITA 1356/MUM/2019Status: DisposedITAT Mumbai15 November 2021AY 2014-152 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 Tribunal allowed the assessee to withdraw the appeal as the issues were covered by the APA. The Learned DR had no objection to the withdrawal.

What were the facts?

The assessee had entered into an Advance Pricing Agreement (APA) with the CBDT covering the impugned assessment year. The grounds of appeal raised by the assessee before the ITAT involved only transfer pricing issues.

What were the issues?

Whether an appeal involving transfer pricing issues can be withdrawn by the assessee when such issues are covered by an Advance Pricing Agreement (APA).

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “K” MUMBAI

Before: SHRI C.N. PRASAD & SHRI S. RIFAUR RAHMAN

For Appellant: Mr. Harshavardhan Bapat, AR
For Respondent: Mr. Kiran Unavekar, DR
Hearing: 11/11/2021Pronounced: 15/11/2021

ORDER PER S. RIFAUR RAHMAN, A.M. The present appeal is filed by the assessee against the order of the Dispute Resolution Panel-2, Mumbai [in short ‘DRP’] for the assessment year 2014-15 and arises out of assessment completed u/s 143(3) r.w.s. 144C(1) of the Income Tax Act, 1961 (in short the Act).

2.

At the time of hearing, the Ld. AR of the assessee submitted that the assessee has entered into an Advance Pricing Agreement (‘APA’) with the Central Board of Direct Taxes (‘CBDT’) on 19th March 2019 which covers the impugned assessment year i.e. assessment year 2014-15. He submitted that the Diversey India Hygiene Pvt. Ltd. 2 ITA No. 1356/M/2019

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