This document analyzes the proceedings and conclusion of ITA 194/DEL/2019, involving The Mitre Corporation, a U.S.-based entity, and the Deputy Commissioner of Income Tax (International Taxation), New Delhi, concerning the assessment year 2015-16.
The appeal by The Mitre Corporation challenged an order from DRP-2, New Delhi. However, it was later withdrawn by the appellant citing their choice to settle the tax disputes under the Vivad Se Vishwas Scheme, 2020.
The case was heard through video conferencing, reflecting the adaptations in judicial processes due to external circumstances such as the pandemic. The appeal was set for a virtual hearing, but no representative for the appellant appeared. Instead, a withdrawal request was submitted via email, indicating their participation in the Vivad Se Vishwas Scheme to resolve the dispute.
The withdrawal of the appeal under the Vivad Se Vishwas Act, 2020, illustrates the significant impact of this resolution scheme on international tax disputes. This Act allows for a streamlined and non-contentious resolution of tax arrears, offering a clear path for corporations to settle disputes without prolonged litigation.
The dismissal of the appeal as withdrawn marks a concise end to this particular litigation, setting a precedent for similar cases where entities may opt for governmental schemes over tribunal adjudications to expedite dispute resolution.
Review of ITA 194/DEL/2019: The Mitre Corporation vs. DCIT (International Taxation), New Delhi
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