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Facts
The assessee, Discovery Network Asia Pacific Pte Ltd., filed an appeal for AY 2020-21. The issues in the appeal were subject to a Mutual Agreement Procedure (MAP) between the Indian and Singapore Competent Authorities, which resulted in a resolution acceptable to the assessee.
Held
In light of the MAP resolution and as per Rule 44G(8) of the Income-tax Rules, 1962, the assessee requested to withdraw the appeal. The Ld. DR had no objection, and the Tribunal permitted the withdrawal, dismissing the appeal as withdrawn.
Key Issues
Whether the assessee should be permitted to withdraw its appeal before the ITAT following a resolution under the Mutual Agreement Procedure (MAP) between India and Singapore.
Sections Cited
Rule 44G(8) of the Income-tax Rules, 1962, Article 27 of the India Singapore Double Taxation Avoidance Agreement ('DTAA')
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH “D” NEW DELHI
Before: SHRI CHALLA NAGENDRA PRASAD & DR. B.R.R KUMAR
सुनवाईक�तारीख/ Date of hearing: 29.01.2024 29.01.2024 उ�ोषणाक�तारीख/Pronouncement on आदेश /O R D E R PER C.N. PRASAD, J.M.
This appeal by assessee has been directed against the order dated 26.04.2023 for AY 2020-21.
The assessee furnished a letter stating that he desires to withdraw the appeal for the assessment year 2020-21. The contents of the letter are as under:
I.T.A.No.1886/Del/2023
I.T.A.No.1886/Del/2023
The Ld. DR has no objection in assessee withdrawing his appeal.
Considering the submissions of the assessee in his letter, we permit the assessee to withdraw his appeal. Accordingly, the appeal is dismissed as withdrawn.
In the result, the appeal is dismissed as withdrawn.
Order pronounced in the open court on 29/01/2024.