Yaskawa India (P.) Ltd. v. ACIT (2019) 179 ITD 33 (Bang) (Trib.)

S.92C:Transfer pricing – Assessee accepted MAP resolution arrived at between competent authorities of India and Japan, issues raised in appeal became infructuous and, thus, same were to be dismissed as withdrawn. [ S.254(1) ]

Assessee is engaged in business of manufacturing and trade of various types of inventors, servers and other electric products .During relevant year, assessee entered into various international transactions with its Associated enterprises . TPO made adjustment to assessee’s ALP in respect of its manufacturing segment . DRP confirmed said addition . In course of appellate proceedings, assessee pointed out that it had accepted MAP resolution arrived at by competent authorities of India and Japan and, thus, asessee wanted to withdraw grounds raised on transfer pricing issues . Accordingly the Tribunal held transfer pricing issue raised by assessee became infructuous and, thus, same was to be dismissed as withdrawn.  ( AY. 2012-13)