Facts of the Case
The appellant, Convergys Customer Management Group Inc., had
filed multiple Income Tax Appeals before the Delhi High Court pertaining to
various assessment years involving international taxation disputes. During the
pendency of these appeals, the dispute between the assessee and the Indian tax
authorities was resolved through the Mutual Agreement Procedure (MAP) under the
Indo-US Double Taxation Avoidance Agreement.
The Competent Authority of India (CBDT) issued an order of
resolution under Section 90 of the Income Tax Act read with Article 27 of the
India-USA DTAA for Assessment Years 2002-03 to 2004-05 and 2006-07 to 2012-13.
Following such resolution, the assessee accepted the settlement and initiated
withdrawal of the pending appeals before the High Court and the Income Tax
Appellate Tribunal.
Issues Involved
- Whether
pending tax appeals could be withdrawn after settlement of disputes
through Mutual Agreement Procedure (MAP).
- Whether
the Revenue’s connected appeals could also be dismissed as withdrawn upon
the same settlement framework.
- Whether
the MAP resolution under Section 90 and Article 27 of the DTAA attained
binding effect upon acceptance by the assessee.
Petitioner’s Arguments
- The
appellant submitted that the tax dispute had been amicably resolved
through the Mutual Agreement Procedure under the Indo-US DTAA.
- It
was argued that the resolution settled the issues involved in the pending
appeals.
- In
light of the settlement, the appellant sought permission to withdraw the
pending appeals.
Respondent’s Arguments
- The
Revenue informed the Court that several connected appeals filed by both
the Revenue and the assessee were also covered under the same MAP
settlement.
- The
Revenue placed on record communication from the Deputy Commissioner of
Income Tax (International Taxation), confirming the CBDT’s resolution
order.
- The
Revenue submitted that instructions had been received to withdraw the
related appeals as well.
Court Findings / Court Order
The Delhi High Court observed that the dispute had already
been settled under the Mutual Agreement Procedure under the Indo-US Double
Taxation Avoidance Agreement and the assessee had formally accepted the
resolution.
Accordingly:
- The
applications seeking withdrawal of appeals were allowed.
- The
assessee’s appeals were dismissed as withdrawn.
- The
Revenue’s connected appeals, being covered under the same MAP settlement,
were also dismissed as withdrawn.
Important Clarification
The Court clarified that once a tax dispute is resolved
through the Mutual Agreement Procedure under Section 90 of the Income Tax Act
and the relevant DTAA provisions, and such resolution is accepted by the
assessee, continuation of parallel judicial proceedings becomes unnecessary.
This order reinforces the binding and effective nature of MAP settlements in
international taxation disputes.
Sections Involved
- Section
90, Income Tax Act, 1961
- Article
27, India-USA Double Taxation Avoidance Agreement (DTAA)
- Mutual
Agreement Procedure (MAP) Framework
Link to download the order -https://delhihighcourt.nic.in/app/case_number_pdf/2018:DHC:8711-DB/SRB13032018ITA32014_125651.pdf
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