IN THE INCOME TAX APPELLATE TRIBUNAL (DEHRADUN CIRCUIT BENCH, NEW DELHI) (THROUGH VIDEO CONFERENCING) BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI B.R.R. KUMAR , ACCOUNTANT MEMBER ITA NO. 526/DEL/2018, A.Y. : 2014-15 MI OVERSEAS LTD. 4 TH FLOOR, TOWER C, BUILDING NO. 1 DLF CITY, PHASE II, GURGAON- 122 002 VS DCIT, CIRCLE-1, (INTERNATIONAL TAXATION) DEHRADUN (APPELLANT) (RESPONDENT) (PAN : AADCM8895K ITA NO. 1251/DEL/2018, A.Y. : 2012-13 MI OVERSEAS LTD. NAVI MUMBAI P-21, TTC INDUSTRIAL ESTATE, THANE- BELAPUR ROAD NAVI MUMBAI MAHARASHTRA PIN 400710 VS DCIT, CIRCLE-1, (INTERNATIONAL TAXATION) DEHRADUN (APPELLANT) (RESPONDENT) (PAN : AADCM8895K ASSESSEE BY : SH. SANJAY SHUKLA, CA SH. BHAUMIK SANGHVI, CA REVENUE BY : SH. NAVEEN CHANDRA UPADHYAYA, SR. D R DATE OF HEARING: 12.07.2021 DATE OF PRONOUNCEMENT: 12.07.2021 ITA NO.526, 1251/DEL./2018 2 O R D E R PER B.R.R.KUMAR, ACCOUNTANT MEMBER : THESE TWO APPEALS HAVE BEEN FILED BY THE ASSESSEE AGAINST THE ORDER OF THE LD. CIT(A)-2, NOIDA, DATED 24.10.2017 & 08/12/2017 RESPECTIVELY. 2. AT THE OUTSET, IT WAS BROUGHT TO THE NOTICE OF B ENCH BY THE LD. SR. DR THAT THE ASSESSEE HAS FILED APPLICATION UNDE R THE DIRECT TAX VIVAD SE VISHWAS ACT, 2020 AND HAS ALREADY SUBMITT ED FORM 1 AND 2 AND FORM 3 HAVE BEEN ISSUED BY THE DESIGNATED AUT HORITY. 3. KEEPING IN VIEW THE EXERCISE OF OPTION BY THE AS SESSEE TO OPT FOR THE SCHEME, THE APPEAL OF THE ASSESSEE IS BEING DISMISSED AS INFRUCTUOUS. 4. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS DIS MISSED. ORDER PRONOUNCED IN OPEN COURT ON THIS 12 TH DAY OF JULY, 2021. SD/- SD/- (AMIT SHUKLA) ( DR. B.R.R.KUMAR) JUDICIAL MEMBER ACCOUNTANT MEMBE R *BINITA* DATED : 12/07/2021 COPY FORWARDED TO: 1.APPELLANT 2.RESPONDENT 3.CIT 4.CIT(A)-14, NEW DELHI. 5.CIT(ITAT), NEW DELHI. AR, ITAT NEW DELHI