DEPUTY COMMISSIONER OF INCOME-TAX, PUNE vs. M/S. MAN TRUCKS INDIA PVT. LTD., (FORMERLY: M/S. MAN FORCETRUCKS P.LTD.,), PUNE

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ITA 353/PUN/2016Status: HeardITAT Pune14 February 2022AY 2011-123 pages
AI SummaryWithdrawn

What did the Tribunal hold?

The Tribunal allowed the parties to withdraw their respective appeals. Consequently, all the appeals were dismissed as withdrawn.

What were the facts?

The assessee filed an application to withdraw grounds of appeal related to transfer pricing adjustments. This was due to the execution of a Unilateral Advance Pricing Agreement (APA). The Revenue accepted this position.

What were the issues?

Whether grounds of appeal related to transfer pricing adjustments can be withdrawn following the execution of an Advance Pricing Agreement.

Which sections of the Income-tax Act were involved?

Section 92CC

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH, ‘C’ PUNE

Before: SHRI R.S. SYAL & SHRI PARTHA SARATHI CHAUDHURY

For Appellant: Shri Tushar Patil
For Respondent: Shri Shivaji B. More

Heard together (2 matters)

ITA Nos.454/PUN/2016
ITA No.353/PUN/2016

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

PER BENCH :

1.

This batch of four appeals involves three appeals of the assessee for the assessment years 2011-12, 2013-14 & 2015-16 and one appeal of the Revenue for the assessment year 2011-12.

2 M/s.MAN Trucks India Pvt. Ltd.,

2.

The assessee has filed an application dated 11-02-2022 submitting that a Unilateral Advance Pricing Agreement (in short ‘APA’) has been executed u/s.92CC of the Act and for execution of the APA, the withdrawal of grounds of appeals in relation to transfer pricing adjustment is called for. The ld. DR candidly accepted the position. In view of the foregoing discussion, we allow the parties to withdraw their respective appeals.

3.

In the result, all the appeals are dismissed as ‘withdrawn’. Order pronounced in the Open Court on 14th February, 2022.

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