VISA WORLDWIDE PTE. LIMITED,SINGAPORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-2(2), BANGALORE

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ITA 276/BANG/2021Status: DisposedITAT Bangalore22 January 2024AY 2012-13Bench: SHRI GEORGE GEORGE K (Vice President), SHRI LAXMI PRASAD SAHU (Accountant Member)2 pages
AI SummaryWithdrawn

What did the Tribunal hold?

The assessee's application to withdraw the appeals was accepted. The reason for withdrawal was to resolve the issue under the Mutual Agreement Procedure as per Article 27 of the Agreement between India and Singapore to avoid double taxation.

What were the facts?

The assessee filed appeals against the orders of the DCIT for Assessment Years 2012-13 and 2017-18. The assessee subsequently filed an application to withdraw these appeals.

What were the issues?

Whether the assessee's application to withdraw the appeals for the purpose of resolving the issue under the Mutual Agreement Procedure should be accepted.

Which sections of the Income-tax Act were involved?

Article 27 of the Agreement between the Government of India and the Government of Singapore

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH : BANGALORE

Before: SHRI GEORGE GEORGE K & SHRI LAXMI PRASAD SAHU

For Appellant: Smt. Manasa Ananthan, Advocate
For Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Hearing: 22.01.2024Pronounced: 22.01.2024

Per Bench :

1.

These appeals at the instance of the assessee are directed against two orders of DCIT, Circle – 2(2), dated 21.04.2021 and 19.04.2021. The relevant Assessment Years are 2012-13 and 2017-18 respectively.

2.

Assessee vide application dated 15.01.2024 submitted that assessee wants to withdraw the appeals as the assessee intends to resolve the issue under the “Mutual Agreement Procedure” as per Article 27 of the Agreement between the Government of India and the Government of Singapore to avoid double taxation. The prayer so made is accepted and the appeals are dismissed as withdrawn.

IT(IT)A Nos.276 and 277/Bang/2021 Page 2 of 2

3.

In the result, appeals filed by the assessee are dismissed as withdrawn.

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