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TMI Blog2020 (10) TMI 1357X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessee : Shri Rajan Vohra, Adv For the Revenue : Shri Anupam Kant Garg, CIT-DR ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER The above three separate appeals by the assessee are preferred against three separate orders framed u/s framed u/s 143(3) r.w.s 144C of the Income tax Act, 1961 [hereinafter referred to as 'the Act' for short] pertaining to A.Ys 2006-07, 2007-08 and 2008-09 res ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce u/s 14A of the Act vis a vis computation of book profit u/s 115JB of the Act. 4. The ld. counsel for the assessee pointed out that the dispute relating to the TP adjustment made to the transactions entered into with AE in USA has been settled by Mutual Agreement Procedure [MAP. Copies of the communications were placed on record. It is the say of the ld. counsel for the assessee that to this ex ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... djustment with AEs which are non USA AEs and other corporate grounds, mentioned elsewhere, as the assessee is contemplating to settle the dispute under Vivad se Vishwas Scheme, for the time being we dismiss these grounds as withdrawn with liberty to the assessee to approach the Tribunal and revive the appeal, if for some technical reason the dispute could not be settled under the Vivad se Vishwas ..... X X X X Extracts X X X X X X X X Extracts X X X X
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