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Income Tax Appellate Tribunal, “A” BENCH : BANGALORE
Before: SHRI N.V. VASUDEVAN & SHRI CHANDRA POOJARI
Per N.V. Vasudevan, Vice President
This appeal by the revenue is against the final order of assessment dated 28.01.2016 passed u/s. 143(3) r.w.s. 144C of the Income-tax Act, 1961 [the Act] relating to assessment years 2011-12.
The assessee’s appeal for the AY 2011-12 in came up for consideration before this Tribunal and was disposed of vide consolidated order dated 24.11.2020 on the assessee’s submission seeking withdrawal of the appeal on the ground that issues raised in its appeal have been settled under the Mutual Agreement Procedure (MAP) under Article 27 of the Convention between the Government of United
IT(TP)A No.510/Bang/2016 Page 2 of 2 States of America and the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital. Accordingly, the Tribunal dismissed the appeals of the assessee as withdrawn for AYs 2011-12 & 2012-13. Following the same, the revenue’s appeal for the AY 2011-12 is also dismissed since the issues concerning the appeal has been settled under the MAP as aforesaid.
In the result, the appeal by the revenue is dismissed.
Pronounced in the open court on this 25th day of November, 2020.