DCIT, CIRCLE- 16(2), NEW DELHI vs. MITSUBISHI HEAVY INDUSTRIES INDIA PVT. LTD., NEW DELHI

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ITA 1059/DEL/2018Status: DisposedITAT Delhi27 June 2024AY 2013-14Bench: Dr. B. R. R. Kumar, Accountant Member Sh. Vimal Kumar (Judicial Member)2 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The tribunal held that since the grounds taken in the appeals were duly covered by the APA order, the appeals would no longer require adjudication. Consequently, the appeals were dismissed as infructuous.

What were the facts?

The Revenue and the assessee filed appeals against orders from the CIT(A)-44 dated 30.11.2017. Both parties subsequently submitted that the grounds of appeal were covered by an order of the Advance Pricing Agreement (APA).

What were the issues?

Whether the appeals require adjudication when the grounds of appeal are already covered by an Advance Pricing Agreement (APA) order.

Which sections of the Income-tax Act were involved?

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘I’, NEW DELHI

Before: Dr. B. R. R. KumarSh. Vimal Kumar

For Appellant: Adv. &
Hearing: 26.06.2024Pronounced: 27.06.2024

Heard together (2 matters)

ITA No. 1059/Del/2018
ITA No. 1882/Del/2018

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

ORDER Per Bench: The present appeals have been filed by the Revenue and the assessee against the orders of ld. CIT(A)-44, New Delhi dated 30.11.2017. 2. Owing to the order of the APA, both the parties fairly submitted that the appeals would no longer be required to be adjudicated as the grounds taken up in the appeal have been & 1882/Del/2018 2 Mitsubishi Heavy Industries India Pvt. Ltd. duly covered by the order of the APA. Hence, the appeals are dismissed as infructuous.

Order Pronounced in the Open Court on 27/06/2024.

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