TMI Blog2012 (5) TMI 735X X X X Extracts X X X X X X X X Extracts X X X X ..... sident and Shri Rajendra, Accountant Member Appellant by: Shri Divesh Chawla Respondent by: Shri Pavan V ed O R D E R Per Bench All these appeals are filed at the instance of the assessee companies. The assessees had filed separate letters in each of the appeals under Article 27 of the Double Tax Avoidance Agreement between India and United States in respect of adjustme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n, ordinarily a person competent to file an appeal should also have the liberty to withdraw its appeal unless there are genuine reasons pointed out by the Revenue to show as to why the appeals deserve to be continued. In fact, if the Department is aggrieved by the orders of the lower authorities, they could have either filed cross objections or moved appropriate petitions accordingly. But no such ..... X X X X Extracts X X X X X X X X Extracts X X X X
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