TATA CONSULTANCY SERVICES LTD,MUMBAI vs. ASST CIT RG 14(1)(2), MUMBAI

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ITA 528/MUM/2016Status: DisposedITAT Mumbai02 March 2021AY 2011-124 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 noted that the assessee had filed the necessary declarations under the DTVSV Scheme and received acceptance from the Revenue. Consequently, the Tribunal accepted the assessee's request to withdraw the appeals.

What were the facts?

The assessee, Tata Consultancy Services Limited, filed appeals against various orders of the CIT(A). The assessee subsequently opted for the Direct Tax Vivad Se Vishwas Scheme, 2020 (DTVSV).

What were the issues?

The primary issue was whether the appeals could be withdrawn by the assessee due to their opting for the Vivad Se Vishwas Scheme.

Which sections of the Income-tax Act were involved?

Not Applicable

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VIRTUAL COURT

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

For Appellant: Shri Harsh Kothari
For Respondent: Shri Manjunatha Swamy
Hearing: 02.03.2021Pronounced: 02.03.2021

Heard together (2 matters)

ITA.No. 7917/MUM/2010
ITA.No. 8/MUM/2011

Read from the judgment's own cause title. This page is filed under one of them.

(A.Y: 2011-12) & 7402/MUM/2007 ITA.No. 7917/MUM/2010 (A.Y: 2005-06) ITA.No. 8/MUM/2011 (A.Y: 2006-07) Tata Consultancy Services Limited O R D E R PER BENCH

1.

These appeals are filed by the assessee against different orders of Learned Commissioner of Income Tax (Appeals), Mumbai [hereinafter in short “Ld.CIT(A)”] for the A.Ys. 2003-04 to 2006-07 and A.Y. 2011-12.

2.

Assessee filed a letter dated 23rd February, 2021 and prayed for withdrawal of appeals. Contents of the letter in ITA.No. 528/Mum/2016 are as under: - “Sub: Withdrawal of appeals before ITAT under Direct Tax Vivaad Se Vishwas Scheme (DTVSV). Re: CMC Limited (Now amalgamated with Tata Consultancy Services Limited) PAN: AAACC2030K Assessment Year: 2011-12 Appeal No. Assessee Appeal No.: 528/Mum/2016 The abovementioned appeals are fixed for hearing before the Honorable 'E ' Bench of Mumbai. In that connection we would like to submit that the appellant has opted for Direct Tax Vivaad Se Vishwas Scheme, 2020 (DTVSV) in respect of abovementioned appeals which are pending before the Hon'ble ITAT Mumbai 'E' Bench. In support of the same, we are attaching the following documents: 1) Form 36 of the assessee appeal - Annexure 1.

(A.Y: 2011-12) & 7402/MUM/2007 ITA.No. 7917/MUM/2010 (A.Y: 2005-06) ITA.No. 8/MUM/2011 (A.Y: 2006-07) Tata Consultancy Services Limited 2) The declaration filed by assessee in Form 1 and 2 filed under DTVSV Scheme - Annexure 2 3) Form 3 issued by PCIT, Mumbai -3 - Annexure 3. In view of the above, as the assessee has opted for DTVSV Scheme in respect of the said appeals, we would like to withdraw these appeals from the Honorable ITAT. Request you to please consider these appeals as withdrawn in view of DTVSV Scheme. Please take the above on record and oblige.”

3.

On a perusal of the above letter and the enclosed copies of Form-3 it is noticed that assessee has already filed declaration and undertaking in Form-1 under Vivad Se Vishwas Scheme and received Form-3 from the Revenue accepting the said declaration. Assessee requested for withdrawal of the appeals. Accepting the request of the assessee for withdrawal of appeals, these appeals are dismissed as withdrawn.

4.

In the result, appeals of the assessee are dismissed as withdrawn.

Order pronounced in the virtual court on 02.03.2021.

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