Pioneer Overseas Corporation India Branch, Hyderabad V. ADIT, New Delhi

ITA 4284/DEL/2012

• Counselvise Citation: [2014] 120 COUNSELVISE.COM (IT) 7375 (ITAT-DELHI)
• Duration Of Justice: 2 year(s) 2 month(s) 22 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 29-10-2014
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: F
• Next Hearing Date: 14-10-2014
• Assessment Year: 2000-2001
• Appeal Filed On: 07-08-2012
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: SANJEEV SHARMA
• Assessee Lawyers: R R MAURAY
• Keywords: Competent authority

Judgement Text

1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : F NEW DELHI BEFORE SHRI H.S.SIDHU , JM AND SHRI J.SUDHAKAR REDDY, AM ITA NO S . 4282 4283 4284 AND 4285 /DEL/201 2 AY : - 1997 - 98, 1999 - 2000, 2000 - 2001 AND 2001 - 2002 PIONEER OVERSEAS CORPORATION INDIA VS. ADIT, CIRCLE 2(1) BRANCH INTERNATIONAL TAXATION 6 - 3 - 1099/1100, BABUKHANS MILLENNIUM NEW DELHI CENTRE, 3 RD FLOOR RAJ BHAVAN ROAD, SOMAJIGUDA HYDERABAD PAN: AAACP 6547 N (APPELLANT) (RESPONDENT) APPELLANT BY : SHRI R.R.MAURAY, ADV. RESPONDENT BY : S H. SANJEEV SHARMA, CIT, DR O R D E R PER J.SUDHAKAR REDDY, ACCOUNTANT MEMBER ALL THESE APPEALS ARE FILED BY THE ASSESSEE PERTAIN ING TO DIFFERENT AYS AND ARE DIRECTED AGAINST A COMMON ORDER OF THE LD.CIT(A) - XXIX, NEW DELHI DT. 20.6.2012. 2. THE LD.COUNSEL FOR THE ASSESSEE FILED THE FOLLOWING LETTER FOR WITHDRAWAL OF THE APPEALS. SUB: APPLICATION FOR WITHDRAWAL OF THE CAPTIONED AP P E ALS FILED ON 7.8.2012. SIR, CAPTIONED APPEALS OF THE ASSESSEE WAS EARLIER LISTED FOR HEARING ON 10.12.2012. AT THE REQUEST OF THE ASSESSEE, THE SAID APPEAL WAS BLOCKED FOR ONE YEAR. IN THIS REGARD, IT IS SUBMITTED THAT WITH A VIEW TO AVOID PROTRACTED LITIGATION AND TO OBTAIN TAX CRE DIT FOR THE INDIAN INCOME FROM THE IRS, USA, OUR CLIENT, M/S PIONEER OVERSEAS CORPORATION, U.S.A. HAS DECIDED TO ACCEPT THE MAP ORDER PASSED BY THE COMPETENT AUTHORITY UNDER ARTICLE 27 OF THE CONVENTION 2 FOR AVOIDANCE OF DOUBLE TAXATION BETWEEN I NDIA & USA AND WITHDRAW THE APPEAL. UNDER INSTRUCTIONS OF THE ASSESSEE, THE UNDERSIGNED HUMBLY PRAYS THAT THE CAPTIONED APPEALS MAY KINDLY BE PERMITTED TO BE WITHDRAWN AND DISMISSED ACCORDINGLY. THANKING YOU. SD/ - (SD KAPILA) ADVOCATE & COUNSEL FOR THE ASSESSEE DT. 10.12.2012, NEW DELHI 3. IN VIEW OF THE ABOVE ALL THESE APPEALS ARE DISMISSED AS WITHDRAWN . 4. IN THE RESULT ALL THESE APPEALS FILED BY THE ASSESSEE ARE DISMISSED AS WITHDRAWN . ORDER PRONOUNCED IN THE OPEN COURT ON 2 9 T H OCTOBER,2014. S D / - S D / - ( H.S. SIDHU ) (J.SUDHAKAR REDDY) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED: THE 2 9 T H OCTOBER , ,2014 *MANGA COPY OF THE ORDER FORWARDED TO: 1. APPELLANT; 2.RESPONDENT; 3.CIT; 4.CIT(A); 5.DR; 6.GUARD FILE BY ORDER ASST. REGISTRAR