SHARP BUSINESS SYSTEMS (INDIA) PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 23(1), NEW DELHI

The ld. Authorized Representative (AR) of assessee has placed on record a copy of communication dated 18.02.2025 from CBDT (Foreign Tax & Tax Research Division) intimating the assessee that Indian and Japanese Competent Authorities have agreed to resolve the MAP in assessee’s case for AY 2008-09 to 2018-19 & 2020-21. In light of the fact that pending issues in appeal have been resolved under MAP, the assessee has requested for withdrawal of its appeals. The ld. AR of assessee further contended that even the issue raised in Department’s appeal for AY 2008-09 is also settled under MAP, therefore, the Department appeal has become infructuous.

Shri Dharm Veer Singh, stated that the issue raised in appeals by the assessee have since been settled under MAP, he has no objection in withdrawal of appeals by the assessee. In so far as the Department appeal, he contended that liberty may be granted to the Department to restore the appeal, if, the issue is not settled under MAP proceedings.

There is a cross appeal by the Revenue for AY 2008-09, the contention of the assessee is that the issues raised in Department’s appeal is also resolved under MAP. Thus, in light of the statement made by Counsel for the assessee, the Department appeal has become infructuous and the same is dismissed as such. Liberty is granted to the Revenue to revive appeal in case the Department finds that the issue in Department’s appeal has not been resolved in MAP.