24/7 CUSTOMER PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE
What did the Tribunal hold?
The Tribunal considered the assessee's application to withdraw the appeal. As there was no objection from the revenue, the appeal was dismissed as withdrawn.
What were the facts?
The assessee had filed an appeal against Transfer Pricing (TP) adjustments. These adjustments were subsequently settled under an agreement between the competent authorities of the United States and India in MAT proceedings.
What were the issues?
The primary issue was whether the appeal should be dismissed as withdrawn, given the settlement of the underlying TP adjustments through an inter-governmental agreement.
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, BANGALORE BENCH A, BANGALORE
Before: SHRI. ABRAHAM P. GEORGE & SHRI. VIJAY PAL RAO
IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCH 'A', BANGALORE BEFORE SHRI. ABRAHAM P. GEORGE, ACCOUNTANT MEMBER AND SHRI. VIJAY PAL RAO, JUDICIAL MEMBER I.T(TP).A No.1064/Bang/2012 (Assessment Year : 2008-09) M/s. 24/7 Customer P. Ltd, Embassy Golflinks Business Park, Chattaghata Village, Off Intermediate Ring Road, Varthur Hobli, Bangalore South Taluk, Bengaluru 560 071 .. Appellant PAN : AAACZ1014A v. Deputy Commissioner of Income-tax (OSD), Circle -11(2), Bengaluru .. Respondent Assessee by : Shri. Darpan Kriplani, CA Revenue by : Shri. G. R. Reddy, CIT- DR-I Heard on : 28.06.2016 Pronounced on : 28.06.2016 O R D E R PER ABRAHAM P. GEORGE, ACCOUNTANT MEMBER :
When this appeal was taken up for hearing, Ld. Counsel for the Assessee submitted that it had filed an application dt.07.01.2016 withdrawing the appeals.
IT(TP)A.1064/Bang/2012 Page - 2
As per the Ld. AR, TP adjustments against which the appeal was filed were settled in the agreement between United States competent authority and Indian competent authority under MAT proceedings. 03. Ld. DR did not raise any objection for the withdrawal. 04. Considering the application of the assessee, we are dismissing the appeal as withdrawn. Order pronounced in the open court on 28th day of June, 2016. Sd/- Sd/- (VIJAY PAL RAO) (ABRAHAM P GEORGE) JUDICIAL MEMBER ACCOUNTANT MEMBER MCN
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