MICROSOFT GLOBAL SERVICES CENTRE INDIA PRIVATE LIMITED,HYDERABAD V. DCIT., CIRCLE-5(1), HYDERABAD

ITA 955/HYD/2024

AI Insights

The case involved Microsoft Global Services Centre India Private Limited, which appealed against a Final Assessment Order passed under various sections of the Income Tax Act, 1961. The dispute was initially addressed by the Disputes Resolution Panel-1 in Bengaluru. However, before the tribunal could deliberate on the substantive issues, the dispute was resolved through the MAP, following a communication from the CBDT. Consequently, the assessee requested to withdraw the appeal, which was unopposed by the CIT-DR for the Revenue.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 792900 (ITAT-HYDERABAD)
• Duration Of Justice: 1 year(s) 1 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 23-09-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB-A
• Assessment Year: 2020-2021
• Appeal Filed On: 22-09-2024
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: U. MINI CHANDRAN
• Assessee Lawyers: PARTH
• Keywords: Transfer pricing

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD “A” BENCH: HYDERABAD BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA G, ACCOUNTANT MEMBER ITA.No.955/Hyd./2024 Assessment Year 2020-2021 Microsoft Global Services Centre India Private Limited, Hyderabad. PIN – 500 032. PAN AAECM2477L Telangana. vs. The DCIT, Circle-5(1), Hyderabad – 500 004 (Appellant) (Respondent) For Assessee : Sri Parth, Advocate For Revenue : Ms. U. Mini Chandran, CIT-DR Date of Hearing : 23.09.2025 Date of Pronouncement : 23.09.2025 ORDER PER VIJAY PAL RAO, V.P. : This appeal filed by the Assessee has been directed against the Final Assessment Order dated 25.07.2024 passed u/sec.143(3) r.w.s.144C(13) r.w.s.144B of the Income Tax Act, 1961 [in short “the Act”] in pursuance to the Directions dated 06.06.2024 of the Disputes Resolution Panel-1, [in short “DRP”], Bengaluru, Printed from counselvise.com 2 ITA.No.955/Hyd./2024 passed u/sec.144C(5) of the Act, for the assessment year 2020-2021. 2. At the time of hearing, Learned Authorised Representative for the Assessee has submitted that the dispute involved in this appeal has been resolved under the MAP as per the Order of the communication of the CBDT dated 11.09.2025 and copy of the same is filed before the Tribunal. Thus, the learned Authorised Representative for the Assessee submitted that the assessee may be allowed to withdraw the present appeal as the dispute has been settled under MAP. 3. The Learned CIT-DR for the Revenue, on the other hand, has no objection if the present appeal of the assessee is dismissed as withdrawn. 4. Considering the submissions of the learned Authorised Representative for the Assessee and the learned CIT-DR for the Revenue, at the outset, we note that the dispute involved in this appeal has been resolved by the Printed from counselvise.com 3 ITA.No.955/Hyd./2024 Competent Authorities of India and US as communicated by the CBDT vide letter dated 11.09.2025 as under : Printed from counselvise.com 4 ITA.No.955/Hyd./2024 5. In view of the fact that the dispute involved in the present appeal of the assessee has already been resolved in the MAP proceedings, accordingly, the assessee is allowed to withdraw the present appeal and consequently, the appeal of the assessee is dismissed as withdrawn. 6. In the result, appeal of the Assessee dismissed as withdrawn. Order pronounced on conclusion of hearing in the open Court on 23.09.2025. Sd/- Sd/- [MANJUNATHA G.] [VIJAYPAL RAO] ACCOUNTANT MEMBER VICE PRESIDENT Hyderabad, Dated 23rd September, 2025 VBP Printed from counselvise.com 5 ITA.No.955/Hyd./2024 Copy to 1. Microsoft Global Services Centre India Private Limited, Building-1, Microsoft Campus, Gachibowli, Hyderabad. PIN – 500 032. Telangana. 2. The DCIT, Circle-5(1), IT Towers, Hyderabad – 500 004 Telangana. 3. The Disputes Resolution Panel-1, 4th Floor, Kendriya Sadan, C-Wing, BENGALURU – 560 034. Karnataka. 4. The Pr. CIT, Hyderabad. 5. The Addl./Joint Commissioner of Income Tax, Transfer Pricing Officer, Aaykar Bhawan, Opp. LB Stadium, Basheerbagh, Hyderabad – 500 004. Telangana. 6. The DR ITAT “A” Bench, Hyderabad. 7. Guard File. //By Order// //True Copy// Printed from counselvise.com "