JCIT (OSD) (IT)- 4(2)(2), MUMBAI vs. SOCIETE INTERNATIONAL DE TELECOMMUNICATIONS AERONUITIQUES SC (S.I.T.A), MUMBAI

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ITA 995/MUM/2020Status: DisposedITAT Mumbai14 July 2021AY 2011-122 pages
AI SummaryWithdrawn

What did the Tribunal hold?

The Tribunal noted that the assessee had successfully resolved the dispute under the Vivad se Vishwas scheme, rendering the revenue's appeals infructuous. The appeals were dismissed as withdrawn.

What were the facts?

The revenue filed appeals against the CIT(A) orders for AY 2010-11 and 2011-12. The assessee had filed an application under the Vivad se Vishwas Act, 2020, and deposited the disputed tax.

What were the issues?

Whether the revenue's appeals are rendered infructuous due to the assessee's settlement under the Vivad se Vishwas Act.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “I” MUMBAI

Before: SHRI RAJESH KUMAR & SHRI RAVISH SOOD

For Respondent: Shri Vijay Kumar Subramaniyam, D.R
Hearing: 14/07/2021Pronounced: 14/07/2021

ORDER PER RAVISH SOOD, J.M: The captioned appeals filed by the revenue are directed against the respective orders passed by the CIT(A)-55, Mumbai, dated 15.11.2019, which in turn arises from the orders passed by the A.O under Sec.143(3) r.w.s 144C(3) of the Income-tax Act, 1961 for A.Y. 2010-11 & 2011-12.

2.

The assessee has filed a letter dated 12.07.2021, wherein it is stated that it has filed an application under the Direct Tax Vivad se Vishwas Act, 2020 and had deposited the disputed tax with respect to the captioned appeals. It is further stated that ‘Form 3’ under Sec. 5(1) of the Vivad se Vishwas Act, 2020 has been issued by the designated authority. Also, it is stated by the assessee that as the amount payable as per ‘Form 3’ had been deposited, therefore, ‘Form 5’ has been issued by the designated authority for both the aforementioned years (copies of ‘Form 3’ and ‘Form 5’ had been enclosed). It is submitted by the assessee that in the backdrop of the aforesaid facts the captioned appeals filed by the revenue having been rendered as infructuous, thus, be deemed to have been withdrawn and accordingly dismissed. & 996/Mum/2020 A.Ys. 2010-11 & 2011-12 2 JCIT (OSD) (IT)-4(2)(2) Vs. Societe International De Telecommunications Aeronautiques SC (SITA)

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