Income Tax Appellate Tribunal - Hyderabad
Deloitte Consulting India Private ... vs Dy. Commissioner Of Income Tax , ... on 3 February, 2020
IN THE INCOME TAX APPELLATE TRIBUNAL
HYDERABAD BENCHES "A" : HYDERABAD
BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER
AND
SHRI A. MOHAN ALANKAMONY, ACCOUNTANT MEMBER
ITA No. A.Y. Appellant Respondent
Deloitte & Touche Deputy/Assistant
Assurance and Enterprise Commissioner of
295/Hyd/17 2012-13 Risk Services India Income Tax,
1991/Hyd/17 2013-14 Private Limited, Circle-17(1),
2371/Hyd/18 2014-15 HYDERABAD HYDERABAD
[PAN: AABCD9794N]
Deloitte Financial Asst. Commissioner of
296/Hyd/17 2012-13 Advisory Services India Income Tax,
1952/Hyd/17 2013-14 Private Limited, Circle-17(1),
HYDERABAD HYDERABAD
[PAN: AABCD9760C]
Deloitte Support Services Deputy/Assistant
294/Hyd/17 2012-13 India Private Limited, Commissioner of
1953/Hyd/17 2013-14 HYDERABAD Income Tax,
2368/Hyd/18 2014-15 [PAN: AABCD9761D] Circle-17(1),
HYDERABAD
Deloitte Consulting India Dy. Commissioner of
Private Limited, Income Tax,
2369/Hyd/18 2014-15 HYDERABAD Circle-17(1),
[PAN: AABCD0476H] HYDERABAD
Deloitte Tax Services Deputy/Assistant
297/Hyd/17 2012-13 India Private Limited, Commissioner of
2190/Hyd/17 2013-14 HYDERABAD Income Tax,
2370/Hyd/18 2014-15 [PAN: AABCD9771F] Circle-17(1),
HYDERABAD
Assistant Commissioner Deloitte Tax Services
37/Hyd/18 2013-14 of Income Tax, India Private Limited,
Circle-17(1), HYDERABAD
HYDERABAD [PAN: AABCD9771F]
For Assessee : NONE
For Revenue : Shri Ashok Kumar Kardham, DR
Date of Hearing : 03-02-2020
Date of Pronouncement : 03-02-2020
ORDER
PER BENCH :
These are appeals by the respective assessees for the AYs.2012-13, 2013-14 & 2014-15 and one appeal by the Revenue for the AY.2013-14. For all these appeals, the assessee has filed a :- 2 -:
Deloitte & Touche Assurance & Enterprise Risk Services India P.Ltd Deloitte Financial Advisory Services India P.Ltd Deloitte Support Services India P.Ltd Deloitte Consulting India P.Ltd Deloitte Tax Services India P.Ltd letter dated 23-01-2020, stating that the Mutual Agreement Procedure (MAP) proceedings between the Government of the United States of America and the Government of Republic of India have concluded and the issues involved in these appeals have been resolved and pursuant to the said resolution, the assessee received a letter dt.07-12-2019, in response to which, the assessee filed a letter of acceptance dt.02-01-2020, accepting the MAP resolution. Therefore, the assessee wishes to withdraw the appeals filed relating to the issues covered under the MAP. Copies of the relevant letters are also filed before us.
2. Since the issues involved in the assessment years before us are covered by the MAP proceedings, all these appeals of the assessee are dismissed as withdrawn and the appeal of Revenue is also dismissed as infructuous.
3. In the result, all the appeals of assessees and the appeal of Revenue are dismissed.
Order pronounced in the open court on 3 rd February, 2020 Sd/- Sd/-
( A. MOHAN ALANKAMONY ) ( P. MADHAVI DEVI ) ACCOUNTANT MEMBER JUDICIAL MEMBER
Hyderabad, Dated 3rd February, 2020 TNMM :- 3 -:
Deloitte & Touche Assurance & Enterprise Risk Services India P.Ltd Deloitte Financial Advisory Services India P.Ltd Deloitte Support Services India P.Ltd Deloitte Consulting India P.Ltd Deloitte Tax Services India P.Ltd Copy to :
1. M/s.Deloitte & Touche Assurance and Enterprise Risk Services India Private Limited, RMZ Futura, Block-A, 2nd Floor, Plot Nos.14 & 15, Road No.2, Hitech City Layout, Madhapur, Hyderabad.
2. Deloitte Financial Advisory Services India Private Limited, RMZ Futura, Block-A, 2nd Floor, Plot Nos.14 & 15, Road No.2, Hitech City Layout, Madhapur, Hyderabad.
3. Deloitte Support Services India Private Limited, RMZ Futura, Block-B, 2nd Floor, Plot Nos.14 & 15, Road No.2, Hitech City Layout, Madhapur, Hyderabad.
4. Deloitte Consulting India Private Limited, RMZ Futura, Block-A, 4th Floor, Plot Nos.14 & 15, Road No.2, Hitech City Layout, Madhapur, Hyderabad.
5. Deloitte Tax Services India Private Limited, RMZ Futura, Block-B, 2nd Floor, Plot Nos.14 & 15, Road No.2, Hitech City Layout, Madhapur, Hyderabad.
6. The Deputy Commissioner of Income Tax, Circle-17(1), Hyderabad.
7. The Asst. Commissioner of Income Tax, Circle-17(1), Hyderabad.
8. Dispute Resolution Panel (DRP)-1, Bengaluru.
9. Director of Income Tax (IT & TP), Hyderabad.
10. Addl. Commissioner of Income Tax (Transfer Pricing), Hyderabad.
11. D.R. ITAT, Hyderabad.
12. Guard File.