M/S SAMSUNG R & D INSTITUTE INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

At the time of hearing, the learned AR of the assessee submitted that letter dated 19th November, 2020 was filed stating that the assessee is opting for Vivad Se Vishwas Scheme, 2020. In the course of hearing, it was the proposition put forward by the Bench that under these facts the appeals of the assessee may be dismissed and withdrawn and liberty may be granted to the assessee to approach this Tribunal for recall of this order under section 254(2) of the Act in case the assessee finally opts out of Vivad Se Vishwas Scheme, 2020. In reply, it was submitted by learned AR of the assessee that if the liberty is granted to the assessee, then assessee has no objection about dismissal of the appeals as withdrawn. Learned DR of the Revenue has no objection on the proposition.

In view of above discussions, we dismiss these appeals as withdrawn and grant liberty to the assessee to approach this Tribunal for recall of this Tribunal order under section 254(2) of the Act in case the assessee finally opts out of Vivad Se Vishwas Scheme, 2020, for any reason in accordance with law.

In the result, both the assessee’s appeals are dismissed.