Grid Solutions SAS (Earlier known as "Alstom Grid SAS"), Chennai V. DCIT (International Taxation), Circle-1(1)(1), New Delhi

ITA 193/DEL/2018

• Counselvise Citation: [2021] 108 COUNSELVISE.COM (IT) 7961 (ITAT-DELHI)
• Duration Of Justice: 3 year(s) 2 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 31-03-2021
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: C
• Assessment Year: 2012-2013
• Appeal Filed On: 08-01-2018
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: M BARANWA L SENIOR
• Assessee Lawyers: DEEPAK THACKER
• Section: 13

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL DELHI DELHI DELHI DELHI BENCH BENCH BENCH BENCH A AA A : NEW DELHI : NEW DELHI : NEW DELHI : NEW DELHI (THROUGH VIDEO CONFERENCING) (THROUGH VIDEO CONFERENCING) (THROUGH VIDEO CONFERENCING) (THROUGH VIDEO CONFERENCING) BEFORE SHRI G.S. PANNU BEFORE SHRI G.S. PANNU BEFORE SHRI G.S. PANNU BEFORE SHRI G.S. PANNU, ,, , VICE PRESIDENT AND VICE PRESIDENT AND VICE PRESIDENT AND VICE PRESIDENT AND SHRI SHRI SHRI SHRI KUL BHARAT KUL BHARAT KUL BHARAT KUL BHARAT , JUDICIAL MEMBER , JUDICIAL MEMBER , JUDICIAL MEMBER , JUDICIAL MEMBER ITA NO ITA NO ITA NO ITA NO S. S.S. S. 194/DEL/2018 & 193/DEL/2018 194/DEL/2018 & 193/DEL/2018 194/DEL/2018 & 193/DEL/2018 194/DEL/2018 & 193/DEL/2018 ASSESSMENT YEAR ASSESSMENT YEAR ASSESSMENT YEAR ASSESSMENT YEAR S : 20 S : 20 S : 20 S : 20 13 1313 13 - -- - 14 & 2012 14 & 2012 14 & 2012 14 & 2012 - -- - 13 1313 13 M/S G M/S G M/S G M/S G RID SOLUTIONS SAS RID SOLUTIONS SAS RID SOLUTIONS SAS RID SOLUTIONS SAS (EARLIER KNOWN AS ALSTOM (EARLIER KNOWN AS ALSTOM (EARLIER KNOWN AS ALSTOM (EARLIER KNOWN AS ALSTOM GRID SAS), GRID SAS), GRID SAS), GRID SAS), C/O GE T&D INDIA LIMITED, C/O GE T&D INDIA LIMITED, C/O GE T&D INDIA LIMITED, C/O GE T&D INDIA LIMITED, IOC BUIDLING, IOC BUIDLING, IOC BUIDLING, IOC BUIDLING, 19/1 GST ROAD, 19/1 GST ROAD, 19/1 GST ROAD, 19/1 GST ROAD, PALLAVARAM, PALLAVARAM, PALLAVARAM, PALLAVARAM, CHENNAI CHENNAI CHENNAI CHENNAI 600 043. 600 043. 600 043. 600 043. PAN : AAHCA2041H. PAN : AAHCA2041H. PAN : AAHCA2041H. PAN : AAHCA2041H. VS. VS. VS. VS. DEPUTY DEPUTY DEPUTY DEPUTY COMMISSIONER OF COMMISSIONER OF COMMISSIONER OF COMMISSIONER OF INCOME TAX, INCOME TAX, INCOME TAX, INCOME TAX, CIRCLE CIRCLE CIRCLE CIRCLE- -- -1(1)(1), INTERNATIONAL 1(1)(1), INTERNATIONAL 1(1)(1), INTERNATIONAL 1(1)(1), INTERNATIONAL TAXATION, TAXATION, TAXATION, TAXATION, NEW DELHI NEW DELHI NEW DELHI NEW DELHI 110 110 110 110 002. 002. 002. 002. (APPELLANT) (RESPONDENT) APPELLANT BY : SHRI DEEPAK THACKER, ADVOCATE. RESPONDENT BY : SHRI M. BARANWAL, SENIOR DR. DATE OF HEARING : 3 33 31 11 1.03 .03.03 .03.2021 .2021 .2021 .2021 DATE OF PRONOUNCEMENT : 31 3131 31.03 .03.03 .03. .. .2021 2021 2021 2021 ORDER ORDER ORDER ORDER PER G.S. PANNU PER G.S. PANNU PER G.S. PANNU PER G.S. PANNU, ,, , VP VPVP VP : :: : THESE APPEALS BY THE ASSESSEE FOR THE ASSESSMENT Y EARS 2013- 14 AND 2012-13 ARE DIRECTED AGAINST THE ORDER OF LE ARNED CIT(A)-42, NEW DELHI DATED 30 TH OCTOBER, 2017. 2. THE ASSESSEE, VIDE LETTER DATED 10 TH FEBRUARY, 2021 HAS REQUESTED FOR WITHDRAWAL OF THE APPEALS FILED BY IT AND STATED THAT THE ASSESSEE HAS OPTED TO SETTLE THE DISPUTE RELATING T O THE TAX ARREARS FOR THE ASSESSMENT YEARS UNDER CONSIDERATION UNDER THE VIVAD SE VISHWAS SCHEME, 2020. CERTIFICATES TO THIS EFFECT UNDER SE CTION 5(1) OF THE DIRECT TAX VIVAD SE VISHWAS ACT, 2020 HAVE ALSO BEE N FILED. ITA-194 & 193/DEL/2018 2 3. LEARNED SENIOR DR HAS NO OBJECTION. 4. IN VIEW OF THE ABOVE, WE ACCEPT THE REQUEST OF T HE ASSESSEE FOR WITHDRAWAL OF THE APPEALS. 5. IN THE RESULT, THE APPEALS OF THE ASSESSEE ARE D ISMISSED AS WITHDRAWN. ABOVE DECISION WAS ANNOUNCED IN THE PRESENCE OF BOT H THE PARTIES ON CONCLUSION OF VIRTUAL HEARING ON 31 ST MARCH, 2021. SD/- SD/- ( (( ( KUL BHARAT KUL BHARAT KUL BHARAT KUL BHARAT ) )) ) (G.S. PANNU (G.S. PANNU (G.S. PANNU (G.S. PANNU ) )) ) JUDICIAL JUDICIAL JUDICIAL JUDICIAL MEMBER MEMBER MEMBER MEMBER VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VK. COPY FORWARDED TO: - 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(A) 5. DR, ITAT ASSISTANT REGISTRAR