M/s Manhattan Associates (India) Deveopment Centre Private Limited , Bangalore V. The Deputy Commissioner of Income Tax Circle-4(1)(2), Bangalore

ITTPA 3169/BANG/2018

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 5185 (ITAT-BANGALORE)
• Duration Of Justice: 1 year(s) 8 month(s) 2 day(s)
• Appeal Type: Income Tax (Transfer Pricing) Appeal
• Pronouncement Date: 29-07-2020
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 28-07-2020
• Assessment Year: 2014-2015
• Appeal Filed On: 27-11-2018
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: MUZAFFAR HUSSAIN
• Section: 143(3); 144C

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES B BENCH: BANGALORE BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER IT (T.P) A NO. 3169 /BANG/2018 (ASSESSMENT YEAR: 20 14 - 15 ) M/S. MANHATTAN ASSOCIATES (IN DIA) DEVELOPMENT CENTRE PVT. LTD., 710, 171 & 172, PHASE II, EPIP ZONE, BANGALORE - 560 066 .APPELLANT PAN: AADCM0727A VS. DY. COMMISSIONER OF INCOME TAX, CIRCLE 4(1)(2), BA NGALORE. RESPONDENT. ASSESSEE BY: NONE. REVENUE BY: SHRI MUZAFFAR HUSSAIN, CIT (D.R) DATE OF HEARING : 28.07. 20 20. DATE OF PRONOUNCEMENT : 29 .07 .20 20. O R D E R PER SHRI PA VAN KUMAR GADALE, JM : THE ASSESSEE HAS FILED AN APPEAL AGAINST THE A SSESSMENT ORDER PASSED U/S . 143(3) R.W.S. 144C OF THE INCOME TAX ACT, 1961 (THE ACT) DT.24.09.2018 IN PURSUANCE TO THE DIRECTIONS OF DISPUTE RESOLUTION PANEL ORDER UN DER SECTION 144C(5 ) OF THE ACT D T.29.08.2018. 2 IT (TP) A NO. 3169/BANG/2018 2. WE FIND THE REGIONAL FINANCE DIRECTOR OF THE ASSESSEE COMPANY , HAS FILED A LETTER DT.6.5.2020 FOR WITHDRAWAL OF AP PEAL PURSUANT TO THE ASSESSEE COMPANY ENTERED IN TO A BILATERAL ADVANCE PRICING AGREEMENT ( APA) WITH THE CB DT ON 2 8.02 .2020 AND THE COPY OF THE LETTER IS EXTRACTED AS UNDER: 3 IT (TP) A NO. 3169/BANG/2018 FURTHER, THE LEARNED DEPARTMENTAL REPRESENTATIVE HAS NO OBJECTION FOR THE WITHDRAWAL OF THE APPEAL. 4 IT (TP) A NO. 3169/BANG/2018 3. WE HEARD THE SUBMISSIONS AND PERUSED THE MATERIAL ON RE CORD. IN VIEW OF SU BMISSION OF LETTER DT. 6.5. 2020 FOR WITHDRAWAL OF APPEAL BY THE ASSESSEE COMPANY , THE APPEAL IS TREATED AS WITHDRAWN AND DISMISSED. 4. IN THE RESULT, APPEAL OF THE ASSESSEE IS DISMISSED. PRONOUNCED IN THE OPEN COURT ON THE DATE MENTIONED ON THE CA PTION PAGE. SD/ - SD/ - ( B.R. B ASKARAN ) (PAVAN KUMAR GADALE) ACCOUNTANT MEMBER JUDICIAL MEMBER DATED: 29 .07. 20 20 . *REDDY GP COPY TO 1. THE APPELLANT 2. THE RESPONDENT 3. CIT (A) 4. PR. CIT 5. DR, ITAT, BANGALORE. 6. GUARD FILE BY ORDER ASSISTANT REGISTRAR INCOME - TAX APPE LLATE TRIBUNAL BANGALORE