Seneca Global IT Services Private Limited, Hyderabad V. DCIT, Circle -3(1), Hyderabad

ITA 306/Hyd/2021

AI Insights

The case involved Seneca Global IT Services (P) Ltd., which appealed against an order passed under sections 143(3) read with section 144C(13) and sections 144C(13) read with sections 143(3A) & 143(3B) of the Income Tax Act for the Assessment Year 2016-17. During the hearing, the assessee's counsel requested to withdraw the appeal following the acceptance of a resolution under the India-US DTAA. The resolution pertained to a mutual agreement procedure (MAP) which the assessee accepted, leading to the withdrawal of the appeal.

• Counselvise Citation: [2023] 140 COUNSELVISE.COM (IT) 128885 (ITAT-HYDERABAD)
• Duration Of Justice: 2 year(s) 1 month(s) 9 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 30-08-2023
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB-A
• Next Hearing Date: 30-08-2023
• Assessment Year: 2016-2017
• Appeal Filed On: 21-07-2021
• Laws Referred To: Income Tax Act
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Assessee Lawyers: C.A ARUN UTPAL SEN
• Section: 143(3)

Judgement Text

ITA 306 of 2021 Seneca Global IT Services P Ltd Page 1 of 2 आयकर अपीलȣय अͬधकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A ‘ Bench, Hyderabad Before Shri R.K. Panda, Vice-President AND Shri Laliet Kumar, Judicial Member ITA No.306/Hyd/2021 Assessment Year: 2016-17 Seneca Global IT Services (P) Ltd., Hyderabad PAN:AALCS3362B Vs. Dy. C. I. T. Circle 3(1) Hyderabad (Appellant) (Respondent) Assessee by : C.A Arun for C.A. Utpal Sen Revenue by: Smt.Vijaya Lakshmi, CIT(DR) Date of hearing: 31/08/2023 Date of pronouncement: 31/08/2023 ORDER Per R.K. Panda, Vice-President This appeal filed by the assessee is directed against the order dated 31.03.2021 passed u/s 143(3) r.w.s 144C(13) and 144C(13) r.w.s. 143(3A) & 143(3B) of the I.T. Act for the A.Y.2016- 17. 2. At the time of hearing, the learned Counsel for the assessee filed an application seeking withdrawal of the appeal on the ground that the assessee has accepted the resolution arrived at under Article 27 of India-US Double Taxation Avoidance Agreement (DTAA). Since the assessee has accepted the MAP Resolution, the learned Counsel for the assessee submitted that the assessee should be allowed to withdraw the appeal. ITA 306 of 2021 Seneca Global IT Services P Ltd Page 2 of 2 2.1 In absence of any objection from the side of the learned DR, the request of the assessee seeking permission of the Bench for withdrawal of the appeal is accepted and the appeal is dismissed as “withdrawn”. 3. In the result, appeal filed by the assessee is dismissed. Order pronounced in the Open Court at the time of hearing itself i.e. on 31 st August, 2023. Sd/- Sd/- (LALIET KUMAR) JUDICIAL MEMBER (R.K. PANDA) VICE-PRESIDENT Hyderabad, dated 31 st August, 2023. Vinodan/sps Copy to: S.No Addresses 1 Seneca Global IT Services (P) Ltd, 2 nd Floor, Studios 7 & 8 Jyothi Pinnacle, Survey No.11, Kondapur, Hyderabad 500084 2 Dy.CIT-Circle 3(1) Signature Towers, Kondapur, Hyderabad 3 Pr. CIT - Hyderabad 4 DR, ITAT Hyderabad Benches 5 Guard File By Order