YASKAWA INDIA PRIVATE LIMITED,BANGALORE V. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT AND DEPUTY COMMISSIONER OF IT, CIRCLE 7(1)(1), BANGALORE, BANGALORE

ITTPA 1804/BANG/2024

AI Insights

Yaskawa India Private Limited filed an appeal against the order of the Assessing Officer (AO) regarding transfer pricing adjustments for the assessment year 2020-21. The appeal was related to transactions with associated enterprises in Japan. Prior to the hearing, the assessee submitted an application to withdraw the appeal, citing a resolution reached under the Mutual Agreement Procedure (MAP) of the India-Japan Double Taxation Avoidance Agreement. The Tribunal noted the resolution and the assessee's acceptance of it, leading to the dismissal of the appeal as withdrawn.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 831271 (ITAT-BANGALORE)
• Duration Of Justice: 1 year(s) 4 month(s) 2 day(s)
• Appeal Type: Income Tax (Transfer Pricing) Appeal
• Pronouncement Date: 20-01-2026
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: C
• Assessment Year: misc
• Appeal Filed On: 18-09-2024
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: DIVYA K.J.
• Assessee Lawyers: WAY
• Keywords: Transfer pricing; Competent authority
• Section: 143(3)

Judgement Text

"IT(TP)A No.1804/Bang/2024 Yaskawa India Private Limited, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER IT(TP)A No.1804/Bang/2024 Assessment Year: 2020-21 Yaskawa India Private Limited 17A, Electronic City Phase I Hosur Road Bengaluru 560 100 PAN NO : AAACY4408P Vs. DCIT Circle 7(1)(1) Bengaluru APPELLANT RESPONDENT Appellant by : None Respondent by : Dr. Divya K.J., D.R. Date of Hearing : 19.01.2026 Date of Pronouncement : 20.01.2026 O R D E R PER KESHAV DUBEY, JUDICIAL MEMBER: This appeal at the instance of the assessee is directed against the order of ld. AO, Assessment Unit, Income Tax Department vide DIN No. ITBA/AST/S/143(3)/2024-25/1066952791(1) dated 23.7.2024 passed u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (in short “The Act”) for the assessment year 2020-21. 2. The assessee has raised following grounds of appeal: Printed from counselvise.com IT(TP)A No.1804/Bang/2024 Yaskawa India Private Limited, Bangalore Page 2 of 9 Printed from counselvise.com IT(TP)A No.1804/Bang/2024 Yaskawa India Private Limited, Bangalore Page 3 of 9 Printed from counselvise.com IT(TP)A No.1804/Bang/2024 Yaskawa India Private Limited, Bangalore Page 4 of 9 3. None appeared on behalf of the assessee. We noticed that the assessee has filed an application on 15/01/2026 requesting for withdrawal of grounds of appeal filed u/s 253 of the Act in relation to the transfer pricing adjustment in accordance with rule 44G(8) of the Income Tax Rules, 1962 which are reproduced below for ease of reference and convenience: Printed from counselvise.com IT(TP)A No.1804/Bang/2024 Yaskawa India Private Limited, Bangalore Page 5 of 9 Printed from counselvise.com IT(TP)A No.1804/Bang/2024 Yaskawa India Private Limited, Bangalore Page 6 of 9 Printed from counselvise.com IT(TP)A No.1804/Bang/2024 Yaskawa India Private Limited, Bangalore Page 7 of 9 4. On going through the above application for withdrawal of grounds of appeal, we take note of the fact that the assessee had filed an application under the provisions of Article 25 (Mutual Agreement Procedure or “MAP”) of the India-Japan Double Taxation Avoidance Agreement (India-Japan Tax Treaty) in respect of the transfer pricing adjustment made by the AO towards the transaction undertaken by the assessee with its Associated Enterprises in Japan. We also take note of the fact that the resolution has been arrived at between the competent authority of India and Japan on 17.12.2025 which are reproduced below for ease of reference and record: Printed from counselvise.com IT(TP)A No.1804/Bang/2024 Yaskawa India Private Limited, Bangalore Page 8 of 9 4.1 The assessee vide letter dated 13.1.2026, submitted that it proposes to accept the said resolution so arrived at under the provisions of Article 25 of the India-Japan Tax Treaty for the transfer pricing issue pertaining to the transaction undertaken by the assessee with its Associated Enterprises in Japan as resolved under the MAP. Printed from counselvise.com IT(TP)A No.1804/Bang/2024 Yaskawa India Private Limited, Bangalore Page 9 of 9 4.2 As per Rule 44G of the Rules, orders giving effect to the MAP resolution shall be passed by the AO once all the appeals are withdrawn by the assessee on the issue so resolved under MAP. Accordingly, in line with the condition precedent, the assessee by way of letter dated 13.1.2026 requested to withdraw the ground of appeal pertaining to the issue for which resolution has been arrived at under the MAP between the India and Japan competent authorities. 4.3 The ld. CIT-DR has no objection if the appeal of the assessee is permitted to be withdrawn. 4.4 This being so, as requested by the assessee vide letter dated 13/01/2026, the appeal of the assessee is dismissed as withdrawn. 5. In the result, the appeal filed by the assessee is dismissed. Order pronounced in the open court on 20th Jan, 2026 Sd/- (Prashant Maharishi) Vice President Sd/- (Keshav Dubey) Judicial Member Bangalore, Dated 20th Jan, 2026. VG/SPS Copy to: 1. The Applicant 2. The Respondent 3. The CIT 4. The DR, ITAT, Bangalore. 5 Guard file By order Asst. Registrar, ITAT, Bangalore. Printed from counselvise.com "