Facts of the Case
- The
assessee, Convergys Customer Management Group Inc., had instituted
multiple appeals before the Delhi High Court concerning international
taxation disputes for several assessment years.
- During
the pendency of these appeals, the Competent Authority of India under the
Central Board of Direct Taxes (CBDT) issued an order of resolution under
the Mutual Agreement Procedure (MAP).
- The
resolution was issued under Section 90 of the Income Tax Act, 1961 read
with Article 27 of the India-USA Double Taxation Avoidance Convention.
- The
assessee accepted the resolution and conveyed its consent for withdrawal
of pending appeals before the High Court and ITAT.
- The Revenue also informed the Court that several departmental appeals arising from the same dispute would also be withdrawn.
Issues Involved
- Whether
tax disputes pending before the High Court could be withdrawn upon
settlement under Mutual Agreement Procedure (MAP) under the Indo-US DTAA?
- Whether
the Revenue’s connected appeals arising out of the same subject matter
should also be permitted to be withdrawn after implementation of MAP
resolution?
- Scope and effect of Section 90 of the Income Tax Act in giving effect to international tax treaty dispute resolutions.
Petitioner’s Arguments
- The
appellant submitted that the tax disputes had been resolved through the
Mutual Agreement Procedure under the Indo-US DTAA.
- The
assessee had formally accepted the resolution communicated by the
Competent Authority.
- In
light of the settlement, continuation of the appeals had become
unnecessary.
- Accordingly,
permission was sought for withdrawal of all pending appeals.
Respondent’s Arguments
- The
Revenue acknowledged the resolution under the Mutual Agreement Procedure.
- It
was submitted that the same settlement covered several connected appeals
filed by the Department as well.
- The
Revenue placed on record the official communication received from the
DCIT, International Taxation Circle, confirming the resolution.
- The Revenue sought permission for withdrawal of its connected appeals as well.
Court Findings / Observations
- The
Delhi High Court took note of the settlement achieved under the Mutual
Agreement Procedure.
- The
Court acknowledged that the assessee had accepted the resolution and had
agreed to withdraw pending litigation.
- The
Court also recorded the Revenue’s statement that related departmental
appeals were covered by the same agreement and were liable to be
withdrawn.
- The Court found no impediment in permitting withdrawal of the appeals.
Court Order / Final Decision
The Delhi High Court allowed the applications and dismissed the appeals as withdrawn in view of the settlement reached under the Mutual Agreement Procedure under the Indo-US DTAA. The connected departmental appeals were also dismissed as withdrawn.
Important Clarification / Legal Significance
- Settlement
under MAP under a DTAA can effectively conclude pending domestic tax
litigation.
- Section
90 of the Income Tax Act empowers implementation of treaty-based dispute
resolution mechanisms.
- Acceptance
of MAP resolution by the assessee has consequential effect on pending
appellate proceedings.
- Both assessee and Revenue may withdraw pending appeals once treaty resolution is implemented.
Sections Involved
- Section 90, Income Tax Act, 1961
- Article 27, India-USA Double Taxation Avoidance Agreement (DTAA)
Link to download the order - https://delhihighcourt.nic.in/app/case_number_pdf/2018:DHC:8711-DB/SRB13032018ITA32014_125651.pdf
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