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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.
Held
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.
Key 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.
Sections Cited
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
Per Bench :
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.
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 The prayer so made is accepted and the appeals are dismissed as withdrawn.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
In the result, appeals filed by the assessee are dismissed as withdrawn.