PEGASYSTEMS WORLDWIDE INDIA PRIVATE LIMITED,HYDERABAD, TELANGANA vs. ACIT CIRCLE-5(1), HYDERABAD
What did the Tribunal hold?
The Tribunal accepted the assessee's request to withdraw the appeal as the BAPA covered the assessment year in question. The Revenue had no objection to the withdrawal.
What were the facts?
The assessee filed an appeal against the order passed by the Assessing Officer. The assessee subsequently entered into a Bilateral Advance Pricing Agreement (BAPA) with the CBDT, which covered the assessment year under appeal.
What were the issues?
Whether an appeal can be withdrawn by the assessee if a subsequent BAPA covers the assessment year under appeal.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, Hyderabad ‘ A ‘ Bench, Hyderabad
Before: Shri Vijay Pal Rao, Vice-Shri Madhusudan Sawdia
आयकर अपील�य अ�धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ A ‘ Bench, Hyderabad �ी �वजय पाल राव, उपा� य� एवं �ी मधुसूदन साव�डया, लेखा सद� य के सम� । Before Shri Vijay Pal Rao, Vice-President A N D Shri Madhusudan Sawdia, Accountant Member आ.अपी.सं /ITA No. 1114/Hyd/2026 (िनधा�रण वष�/Assessment Year: 2022-23) Pegasystems Worldwide Vs. ACIT India Private Limited Circle 5(1) Hyderabad Hyderabad PAN: AAECP3453F (Appellant) (Respondent) िनधा�रती �ारा/Assessee by: CA Deepak Kudapa राज� व �ारा/Revenue by: Smt. B.K. Vishnu Priya, CIT (DR) सुनवाई की तारीख/Date of hearing: 25/06/2026 घोषणा की तारीख/Pronouncement: 25/06/2026 आदेश/ORDER Per Madhusudan Sawdia, A.M.:
This appeal is filed by Pegasystems Worldwide India Private Limited (“the assessee), feeling aggrieved by the order passed by the Learned Assessing Officer under section 143(3) read with section 144C(13) and 144B of the Income Tax Act, 1961 dated 22.01.2026 for the A.Y.2022-23. 2. At the outset, the Learned Authorized Representative (“Ld. AR”) submitted that the assessee is seeking permission to withdraw the present appeal. The
application of the assessee for withdrawal of appeal is reproduced as under:
The Ld. AR submitted that the assessee has entered into a Bilateral Advance Pricing Agreement (“BAPA”) with the Central Board of Direct Taxes (“CBDT”) on 03.02.2026, wherein the Assessment Year 2022-23, being the year under
consideration, is also covered by the said agreement. The assessee has placed on record a copy of the BAPA. In view of the same, the Ld. AR submitted that the assessee does not wish to pursue the present appeal and prayed that the same may be permitted to be withdrawn. 4. The Learned Departmental Representative fairly submitted that the Revenue has no objection if the assessee is permitted to withdraw the present appeal. 5. We have considered the submissions of both the parties and perused the material available on record. Since the assessee has entered into a BAPA with the CBDT covering the assessment year under consideration and has expressed its intention not to pursue the present appeal, we find no reason to decline the request for withdrawal. The assessee has placed on record a copy of the BAPA. Accordingly, the request made by the assessee for withdrawal of the appeal is accepted. 6. In the result, the appeal of the assessee is dismissed as withdrawn. Order pronounced in the Open Court on the conclusion of hearing i.e. on 25th June, 2026. Sd/- Sd/- (VIJAY PAL RAO) (MADHUSUDAN SAWDIA) VICE PRESIDENT ACCOUNTANT MEMBER Hyderabad, dated 25th June, 2026. Vinodan/sps
Copy to:
S.No Addresses 1 Pegasystems Worldwide India (P)Ltd, Building No.12 A, 13th Office Level, Mindspace, Cyberabad Madhapur, Hyderabad 500081 2 ACIIT Circle 5(1) IT Towers, Professor Elyas Burney Road, AC Guards, Masab Tank, Hyderabad 500057 3 Pr. CIT,Hyderabad/Director of Income Tax (International Taxation), Hyderabad 4 DR, ITAT Hyderabad Benches 5 Guard File
By Order
TUMMALACHARLA Digitally signed by TUMMALACHARLA LAKSHMI NARAYANA DN: cn=TUMMALACHARLA LAKSHMI LAKSHMI NARAYANA, c=IN, o=INCOME TAX APPELLATE TRIBUNAL, ou=INCOME TAX NARAYANA APPELLATE TRIBUNAL, CHENNAI BENCH Date: 2026.06.29 11:52:52 +05'30'
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