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Income Tax Appellate Tribunal, “A’’ BENCH : BANGALORE
Before: SHRI B.R BASKARAN & SMT. BEENA PILLAI
O R D E R Per B.R Baskaran, Accountant Member :
The Revenue has filed this appeal challenging the order dated 27-6-2019 passed by Ld CIT(A)-6, Bengaluru and it relates to asst. year 2010-11.
The Revenue is aggrieved by the decision of ld CIT(A) in granting relief to the assessee in respect of transfer pricing adjustments made by the AO.
At the time of hearing, the ld AR submitted that the assessee had applied for Mutual Agreement Procedure (MAP) proceeding for the year under consideration and the same has since been settled
IT(TP)A No.2024 /Bang/2019 by passing resolution order, dated 24-07-2019, passed u/s 90 of the Income tax Act r.w Article 27 of India-US double taxation avoidance convention. The ld AR further submitted that the AO has already given effect to the MAP proceedings, vide its order dated 14/11/2019. Accordingly the ld AR submitted that the original assessment order and appellate order will not survive in view of the MAP resolution order and hence the appeal filed by the Revenue shall become infructuous. The ld AR also furnished copy of asst. order dated 14/11/2019 passed by the AO giving effect to the MAP resolution proceedings.
We heard the ld DR and perused the record. Having regard to the submissions made by the ld AR, the impugned appeal filed by the Revenue shall become infructuous. Accordingly we dismiss the appeal of the assessee as infructuous.
In the result, the appeal of the Revenue is dismissed.
Order pronounced in the Open Court on 3rd January, 2019.