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

....N CHARY, JUDICIAL MEMBER For the Assessee : Shri Rajan Vohra, Adv For the Revenue : Shri Anupam Kant Garg, CIT-DR ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER The above three separate appeals by the assessee are preferred against three separate orders framed u/s framed u/s 143(3) r.w.s 144C of the Income tax Act, 1961 [hereinafter referred to as 'the Act' for short] pertaining....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....orporate tax ground relates to the disallowance u/s 14A of the Act vis a vis computation of book profit u/s 115JB of the Act. 4. The ld. counsel for the assessee pointed out that the dispute relating to the TP adjustment made to the transactions entered into with AE in USA has been settled by Mutual Agreement Procedure [MAP. Copies of the communications were placed on record. It is the say of t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....re dismissed as withdrawn. 6. In respect of TP adjustment with AEs which are non USA AEs and other corporate grounds, mentioned elsewhere, as the assessee is contemplating to settle the dispute under Vivad se Vishwas Scheme, for the time being we dismiss these grounds as withdrawn with liberty to the assessee to approach the Tribunal and revive the appeal, if for some technical reason the dispu....