CSC Technology Singapore Pte. Ltd, Singapore V. Deputy Commissioner of Income-tax, New Delhi

ITA 1463/DEL/2015

• Counselvise Citation: [2021] 109 COUNSELVISE.COM (IT) 9595 (ITAT-DELHI)
• Duration Of Justice: 5 year(s) 9 month(s) 24 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 05-01-2021
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: 2010-2011
• Appeal Filed On: 12-03-2015
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: PRABHA KANT
• Section: 2

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH D, NEW DELHI BEFORE SH. N. K. BILLAIYA, ACCOUNTANT MEMBER AND MS. SUCHITRA KAMBLE, JUDICIAL MEMBER (THROUGH VIDEO CONFERENCING) ITA NO.1463/DEL/2015 & 415 /DEL/2016 ASSESSMENT YEAR: 2010-11 & 2011-12 CSC TECHNOLOGY SINGAPORE PVT. PTE. (FORMERLY KNOWN AS CSC COMPUTER SCIENCES PTE. LTD.) A-44/45, DLF IT PARK, NOIDA TOWER, SECTOR- 62, NOIDA -201301 PAN NO. AABCC9132B VS DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1 (2) (1), INTERNATIONAL TAXATION, 4 TH FLOOR, BLOCK- E2, PARTYAKSH KAR BHAWAN, CIVIC CENTRE, NEW DELHI- 110002 (APPELLANT) (RESPONDENT) APPELLANT BY SH. A. T. PANDA, ADVOCATE RESPONDENT BY SH. PRABHA KANT, CIT DATE OF HEARING: 05/01/2021 DATE OF PRONOUNCEMENT: 05/01/2021 ORDER PER N. K. BILLAIYA, AM: ITA NO.1463/DEL/2015 AND 415/DEL/2016 ARE TWO SEPA RATE APPEALS BY THE ASSESSEE PREFERRED AGAINST TWO SEPAR ATE ORDERS 2 FRAMED U/S. 143 (3) R.W.S. 144 C OF THE ACT DATED 2 6.02.2014 AND 19.11.2015 PERTAINING TO A.Y.2010-11 AND 2011-12 RE SPECTIVELY. 2. AT THE VERY OUTSET THE COUNSEL FOR THE ASSESSEE STATED THAT THE APPELLANT HAS FILED A DECLARATION UNDER VIVAAD SE VISHWAS SCHEME, 2020 TO SETTLE THE DISPUTE. THE COUNSEL STA TED THAT RELEVANT FORMS HAVE ALREADY BEEN FILED. 3. ON SUCH STATEMENT BOTH THESE APPEALS ARE DISMISS ED AS WITHDRAWN. HOWEVER, LIBERTY IS GIVEN TO THE APPELL ANT TO APPROACH THE TRIBUNAL FOR THE REVIVAL OF THE APPEALS IF FOR SOME TECHNICAL REASON THE DISPUTE COULD NOT BE SETTLED UNDER THE V IVAAD SE VISHWAS SCHEME, 2020. 4. ON SUCH CONCESSION BOTH THE APPEALS ARE DISMISSE D. 5. DECISION ANNOUNCED IN THE OPEN COURT IN THE PRES ENCE OF BOTH THE REPRESENTATIVES ON 05.01.2021. SD/- SD/- (SUCHITRA KAMBLE) (N. K. BILLAIYA) JUDICIAL MEMBER ACCOU NTANT MEMBER *NEHA* DATE:- 05.01.2021 COPY FORWARDED TO: 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(APPEALS) 5. DR: ITAT ASSISTANT REGI STRAR ITAT NEW DELHI 3 DATE OF DICTATION 05. 01 .20 21 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 05. 01 .20 21 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE OTHER MEMBER 05. 01 .20 21 DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR.PS/PS 05. 01 .20 21 DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE DICTATING MEMBER FOR PRONOUNCEMENT 05. 01 .20 21 DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR. PS/ PS 05. 01 .20 21 DATE ON WHICH THE FINAL ORDER IS UPLOADED ON THE WEBSITE OF ITAT 05. 01 .20 21 DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 05. 01 .20 21 DATE ON WHICH F ILE GOES TO THE HEAD CLERK. THE DATE ON WHICH FILE GOES TO THE ASSISTANT REGISTRAR FOR SIGNATURE ON THE ORDER DATE OF DISPATCH OF THE ORDER 4