ENTAIN SOFTWARE DEVELOPMENT SERVICES (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-8(1), HYDERABAD
What did the Tribunal hold?
The Tribunal allowed the assessee to withdraw the appeal. Since the APA resolved the issues raised in the appeal and the Revenue had no objection, the appeal was permitted to be withdrawn.
What were the facts?
The assessee filed an appeal against the final assessment order. During the hearing, the assessee sought to withdraw the appeal as they had entered into an Advance Pricing Agreement (APA) with the CBDT covering the assessment year in question.
What were the issues?
Whether the appeal should be withdrawn as the issues are resolved by an Advance Pricing Agreement (APA).
Which sections of the Income-tax Act were involved?
Section 143(3),Section 144C(13),Section 144B,Section 92CA(3)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, Hyderabad “B” Bench, Hyderabad
आदेश / ORDER PER MANJUNATHA G., A.M : This appeal filed by the assessee is directed against the final assessment order passed by the Assessing Officer under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (in short “the Act”), dated 19.01.2026 pursuant to the order of the Learned Transfer Pricing Officer (in short “Ld. TPO”) under section 92CA(3) of the Act, and the Ld. Dispute Resolution Panel (in short “Ld.DRP”) directions dated 08.12.2025 and pertains to the A.Y. 2022-23. 2. At the time of hearing, the learned counsel for the assessee, Ms. Mahima Jain, C.A., submitted that the assessee seeks to withdraw the present appeal in view of the fact that the assessee has entered into an Advance Pricing Agreement (APA) with the Central Board of Direct Taxes (CBDT) on 27.03.2026, which is applicable for A.Ys. 2022-23 to 2026-27. The learned counsel for the assessee submitted that all the international transactions undertaken by the assessee during the year under consideration are covered by the APA and, therefore, the issues raised in the present appeal stand resolved. Accordingly, the assessee does not wish to pursue the appeal any further and requested that the appeal may be permitted to be withdrawn. 3. The learned CIT-DR for the Revenue, Shri Waseem UR Rehman, raised no objection to the said request.
3 ITA No. 1011/Hyd/2026
We have heard both the parties and considered the request of the assessee. Since the assessee seeks to withdraw the appeal on the ground that all the international transactions involved in the year under consideration are covered by the Advance Pricing Agreement (APA) entered into with the Central Board of Direct Taxes (CBDT), and the issues raised in the appeal stand resolved, and as the Revenue has no objection, we permit the assessee to withdraw the appeal. 5. In the result, the appeal filed by the assessee is dismissed as withdrawn.
Order pronounced in the Open Court on 27th July, 2026.
Sd/- Sd/- (श्री रवीश सूद) (मंजूनाथ जी) (RAVISH SOOD) (MANJUNATHA G.) न्याययक सदस्य/JUDICIAL MEMBER लेखा सदस्य/ACCOUNTANT MEMBER Sd/- Hyderabad, dated 27.07.2026. TYNM/sps
4 ITA No. 1011/Hyd/2026
आदेशकी प्रतततिति अग्रेतषत/ Copy of the order forwarded to:- 1. तनर्ााररती/The Assessee : ENTAIN SOFTWARE DEVELOPMENT SERVICES (INDIA) PRIVATE LIMITED, 18TH FLOOR, SKY TWO, PRESTIGE SKY TECH, SURVEY NO.332 (PART) & 333 (PART), PUPPALAGUDA, ISB ROAD, FINANCIAL DISTRICT, HYDERABAD, GACHIBOWLI, K.V. RANGAREDDY, SERI LINGAMPALLY, HYDERABAD-500032, TELANGANA 2. राजस्व/ The Revenue : DCIT, CIRCLE-8(1), O/O DCIT, CIRCLE-8(1), SIGNATURE TOWERS, SY. NO. 6(P) OF KONDAPUR, SY. NO. 37(P) OF KOTHAGUDA,, HYDERABAD-500084, TELANGANA 3. The Principal Commissioner of Income Tax, (IT & TP), Hyderabad. 4. The Disputes Resolution Panel-1, Bangalore 5. तवभागीयप्रतततनतर्, आयकर अिीिीय अतर्करण, हैदराबाद / DR, ITAT, Hyderabad 6. गार्ाफ़ाईि / Guard file
आदेशानुसार / BY ORDER TIRUPATI Digitally signed by TIRUPATI YAMINI NAGA YAMINI NAGA MALLESWARI Date: 2026.07.31 MALLESWARI 17:28:11 +05'30' Sr. Private Secretary ITAT, Hyderabad
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