Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram

TMI Blog

Home

2020 (10) TMI 1357

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... P. Communications from the Government of India, Ministry of Finance, Department of Revenue, CBDT are placed on record. To this extent, the appeals are dismissed as withdrawn. TP adjustment with AEs which are non USA AEs and other corporate grounds - As the assessee is contemplating to settle the dispute under Vivad se Vishwas Scheme, for the time being we dismiss these grounds as withdrawn wi .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ng to A.Ys 2006-07, 2007-08 and 2008-09 respectively. Since all the three appeals pertain to same assessee and were heard together, these are being disposed off by this common order for the sake of convenience and brevity. 2. In all these appeals, the assessee has filed revised and modified grounds of appeal. The main issue is common in all the appeals which relates to TP adjustment made to the .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... the ld. counsel for the assessee that to this extent, the appeals may be allowed to be withdrawn. The ld. counsel for the assessee further stated that in respect of TP adjustment with non USA parties and the corporate grounds, the assesseeiss contemplating to settle the dispute under Vivad se Vishwas Scheme and therefore, if, for some reason the dispute cannot be settled, then the assessee may be .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... pute could not be settled under the Vivad se Vishwas Scheme. 7. With the above directions, all the appeals of the assessee stand dismissed as withdrawn. 8. In the result, all the three appeals of the assessee in ITA No. 5928/DEL/2010, ITA No. 5291/DEL/2011 and ITA No. 6478/DEL/2012 are dismissed as withdrawn. The order is pronounced in the open court on 28.10.2020. - - TaxTMI - TMIT .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

 

 

 

 

Quick Updates:Latest Updates