What did the Tribunal hold?

The Tribunal dismissed the appeal as withdrawn, as no objection was raised by the DR regarding the assessee's application for withdrawal.

The assessee filed an appeal against the order of the TPO. The assessee subsequently filed an application to withdraw the appeal due to a settlement reached between the India and Japan Competent Authorities under the MAP.

What were the issues?

Whether the assessee is permitted to withdraw the appeal due to a settlement under the Mutual Agreement Procedure (MAP) between India and Japan.

Omron Automation Private Limited… vs DCIT | ITAT Delhi 2025

Income Tax Appellate Tribunal, DELHI ‘H’ BENCH,

Before: SHRI MAHAVIR SINGH & SHRI NAVEEN CHANDRA

For Respondent: Shri Om Prakash, Sr. DR

Hearing: 12.09.2025Pronounced: 12.09.2025

PER NAVEEN CHANDRA, ACCOUNTANT MEMBER:-

This appeal by the assessee is directed against the order of the TPO, Delhi dated 30.04.2024 for A.Y 2020-21.

At the very outset, the ld. counsel for the assessee filed an application dated 25.08.2025 seeking permission to withdraw the appeal filed by the assessee on the ground that a settlement has been arrived at between the India and Japan Competent Authorities and in order to communicate its acceptance of the resolution arrived at under the MAP to India CA, the assessee needs to withdraw the pending appeal in respect of issues resolved under the MAP as per Rule 44G(8) of the I.T. Rules, 1962.

The ld. DR did not raise any objection.

Accordingly, the appeal is dismissed as withdrawn.

In the result, the appeal of the assessee in No. ITA 3107/DEL/2024 stands dismissed as withdrawn.

The order is pronounced in the open court on 12.09.2025.

OMRON AUTOMATION PRIVATE LIMITED,GURUGRAM vs. DCIT, CIRCLE-19(1), DELHI

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