JDA SOFTWARE PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BENGALURU

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ITA 2579/BANG/2017Status: DisposedITAT Bangalore03 January 2020AY 2013-142 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 assessee's counsel requested to withdraw the appeal as the assessment year was covered by the APA and its roll-back provisions. The tribunal allowed the withdrawal.

What were the facts?

The assessee company filed an appeal against the DCIT's order for assessment year 2013-14. The assessee later entered into an Advance Pricing Agreement (APA) with the CBDT.

What were the issues?

Whether pending appellate proceedings can be withdrawn if the assessment year is covered by an Advance Pricing Agreement (APA) with roll-back provisions.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH : BANGALORE

Before: SHRI N.V. VASUDEVAN & SHRI A K GARODIA

For Appellant: Shri Kaushik, CA
For Respondent: Shri C.H. Sundar Rao, CIT(DR)(ITAT) Bengaluru
Hearing: 18.12.2019Pronounced: 03.01.2020

Date of hearing : 18.12.2019 Date of Pronouncement : 03.01.2020 O R D E R Per N.V. Vasudevan, Vice President

This appeal by the assessee is against the final order dated 10.10.2017 of the DCIT, Circle 4(1)(1), Bangalore passed u/s. 143(3) r.w.s. 144C of the Income-tax Act, 1961 [the Act] relating to assessment year 2013-14.

2.

At the time of hearing, the ld. counsel for the assessee submitted that the assessee has entered into Advance Pricing Agreement [APA] with the CBDT on 21.11.2019 and the assessment year involved in this appeal is also part of the said agreement. As required under Rule 10RA(4) of the Income-tax Rules, 1962, any pending appellate proceedings which is subject matter of roll back provisions shall be withdrawn by the applicant. Accordingly, the ld. counsel for the assessee has prayed for withdrawing the various grounds raised by the assessee in this appeal.

3.

The appeal is therefore dismissed as withdrawn.

Pronounced in the open court on this 3rd day of January, 2020.

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