Hampson Russel Ltd. Partnership, Dehradun V. DCIT, Circle- I, International Taxation, Dehradun

ITA 5176/DEL/2018

• Counselvise Citation: [2021] 109 COUNSELVISE.COM (IT) 7750 (ITAT-DEHRADUN)
• Duration Of Justice: 2 year(s) 5 month(s) 19 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 20-01-2021
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2014-2015
• Appeal Filed On: 31-07-2018
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: NAVEEN CHANDRA UPADHYAYA

Judgement Text

1 ITA NO. 2557 & 2558/DEL/2016 ITA NO. 5176 & 5177/DEL/2018 IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN CIRCUIT BENCH: DEHRADUN BEFORE SHRI R. K. PANDA, ACCOUNTANT MEMBE R AND MS SUCHITRA KAMBLE, JUDIC IAL MEMBER ITA NO. 2557/DEL/2016 ( A.Y 2011-12) ITA NO. 2558/DEL/2016 ( A.Y 2012-13) (THROUGH VIDEO CONFEREN CING) HAMPSON RUSSEL LTD. C/O. NANGIA & COMPANY SUITE 4A, PLAZA M-6, JASOLA NEW DELHI PAN: AADFH8957J (APPELLANT) VS ADIT INTERNATIONAL TAXATION CIRCLE-1, INCOME TAX OFFICE, SUBHASH ROAD, DEHRADUN (RESPONDENT) ITA NO. 5176/DEL/2018 ( A.Y 2014-15) ITA NO. 5177/DEL/2018 ( A.Y 2015-16) HAMPSON RUSSEL LTD. C/O. NANGLA & CO. A-109, SECTOR-136, NOIDA UTTAR PRADESH PAN: AADFH8957J (APPELLANT) VS DCIT CIRCLE-1, INTERNATIONAL TAXATION AAYAKAR BHAWAN, 13A, SUBHASH ROAD, DEHRADUN (RESPONDENT) APPELLANT BY SH. AMIT ARORA, CA RESPONDENT BY SH. NAVEEN CHANDRA UPADHYAYA, SR. DR ORDER PER SUCHITRA KAMBLE, JM THESE FOUR APPEALS ARE FILED BY THE ASSESSEE AGAINS T THE ORDERS DATED 23/02/2016 PASSED BY CIT(A)-2, NOIDA FOR ASSESSMENT YEARS 2011-12 AND 2012-13 AS WELL AS ORDERS DATED 31/05/2018 PASSED B Y CIT(A)-2, NOIDA FOR ASSESSMENT YEARS 2014-15 AND 2015-16 RESPECTIVELY. DATE OF HEARING 20.01.2021 DATE OF PRONOUNCEMENT 20.01.2021 2 ITA NO. 2557 & 2558/DEL/2016 ITA NO. 5176 & 5177/DEL/2018 2. BEFORE US, THE LD. AR SUBMITTED THAT THE ASSESS EE HAS MOVED AN APPLICATION TO RESOLVE THE PENDING ISSUE THROUGH DI RECT TAX VIVAD SE VISHWASH SCHEME (VSV) ACT, 2020, AND HAS FILED DECLARATION FORM NO. 1 & 2. 3. IN VIEW OF THE AFORESAID FACTS AND AFTER CONSIDE RING THE SUBMISSIONS OF THE ASSESSEE, WE DISMISS THESE APPEALS OF ASSESSEE AS WITHDRAWN SUBJECT TO A CAVEAT THAT IN CASE THE DISPUTE RELATING TO TAX ARR EARS FOR THE CAPTIONED ASSESSMENT YEAR IS NOT ULTIMATELY RESOLVED IN TERMS OF THE AFORESAID ACT, THE ASSESSEE SHALL BE AT LIBERTY TO APPROACH THE TRIBUN AL FOR REINSTITUTION OF THESE FOUR APPEALS AND THE TRIBUNAL SHALL CONSIDER THE SA ME. THE APPEALS OF THE ASSESSEE ARE DISMISSED AS WITHDRAWN. 4. IN THE RESULT, THESE FOUR APPEALS OF THE ASSESSE E ARE DISMISSED. ORDER IS PRONOUNCED IN THE OPEN COURT IN PRESENCE O F BOTH THE PARTIES ON 20 TH JANUARY, 2021. SD/- SD/- (R. K. PANDA) (SUCHITRA KAMBLE) ACCOUNTANT MEMBER JUDICIAL M EMBER DATED: 20/01/2021 R. NAHEED COPY FORWARDED TO: 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(APPEALS) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI 3 ITA NO. 2557 & 2558/DEL/2016 ITA NO. 5176 & 5177/DEL/2018