24/7 Customer Private Limited , Bangalore V. Assistant Commissioner of Income Tax Circle-2(1)(1), Bangalore

ITA 560/BANG/2017

• Counselvise Citation: [2020] 111 COUNSELVISE.COM (IT) 8705 (ITAT-BANGALORE)
• Duration Of Justice: 2 year(s) 10 month(s) 8 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 17-01-2020
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: 2012-2013
• Appeal Filed On: 09-03-2017
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Assessee Lawyers: SUMIT LOHARIWALA FROM A CO
• Keywords: Transfer pricing; International transaction; Competent authority
• Section: 13

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES : A BENCH : BANGALORE BEFORE SHRI. B. R. BASKARAN, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A NO. 560/BANG/2017 ASSESSMENT YEAR : 2012 - 13 M/S. 24/7 CUSTOMER PVT. LTD., PRESTIGE TECH PLATINA 2, SURVEY NOS. 32/1, 32/2, 34/1, 34/2, 34/3, 34/4, KADUBEESANAHALLI VILLAGE, VARTHUR HOBLI, OUTER RING ROAD, BETWEEN SARJAPUR AND MARATHAHALLI, BANGALORE 560 087. PAN NO : AAACZ1014A VS. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1) (1), ROOM NO. 217, 2 ND FLOOR, BMTC BUILDING, KORAMANGALA, BANGALORE 560 095. APPELLANT RESPONDENT APPELLANT BY : SRI. SUMIT LOHARIWALA, FROM A CO., RESPONDENT BY : MS. NEERA MALHOTRA, CIT DR DATE OF HEARING : 14.01.2020 DATE OF PRONOUNCEMENT : 17 .01. 2020 ORDER PER BEENA PILLAI, JUDICIAL MEMBER : PRESENT APPEAL HAS BEEN FILED BY ASSESSEE AGAINST THE FINAL ASSESSMENT ORDER DATED 05/01/17 PASSED BY LD. ACIT CIRCLE 2 (1) (1), BANGALORE. IT(TP)A NO. 560/BANG/2017 A. Y : 2012 13 PAGE 2 OF 3 2. AT THE OUTSET, LD. AR HAS FILED ASSESSEES LETTER DATED 18/12/19 WHEREIN ASSESSEE WISHES TO WITHDRAW PRESENT APPEAL FILED FOR YEAR UNDER CONSIDERATION. THE SAID LETTER FOR WITHDRAWAL HAS BEEN FILED, PURSUANT TO MUTUAL AGREEMENT PROCEDURE REACHED BETWEEN UNITED STATES COMPETENT AUTHORITY AND INDIAN COMPETENT AUTHORITY, WITH REGARD TO TRANSFER PRICING ADJUSTMENT IN RESPECT OF INTERNATIONAL TRANSACTIONS, RELATED TO ITES SEGMENT. 2.1. LD.CIT DR DO NOT OBJECT FOR THE SAME. 3. CONSIDERING THE SUBMISSIONS MADE BY ASSESSEE IN ITS LETTER DATED 18/12/19 FILED BEFORE THIS TRIBUNAL ON 14/01/20, WE ALLOW WITHDRAWAL OF PRESENT APPEAL. ACCORDINGLY, GROUNDS RAISED BY ASSESSEE IN THE PRESENT APPEAL STANDS DISMISSED AS WITHDRAWN. IN THE RESULT, APPEAL FILED BY ASSESSEE STANDS DISMISSED AS WITHDRAWN. ORDER PRONOUNCED IN THE OPEN COURT ON 17 TH JANUARY, 2020. SD/- SD/- (B. R. BASKARAN) (BEENA PILLAI) ACCOUNTANT MEMBER JUDICIAL MEMBER BANGALORE, DATED 17 TH JANUARY, 2020. /MK/ IT(TP)A NO. 560/BANG/2017 A. Y : 2012 13 PAGE 3 OF 3 COPY TO: 1. THE APPLICANT 2. THE RESPONDENT 3. THE CIT 4. THE CIT(A) 5. THE DR, ITAT, BANGALORE. 6. GUARD FILE BY ORDER ASST. REGISTRAR, ITAT, BANGALORE.