CLARIVATE ANALYTICS (INDIA) PVT LTD,MUMBAI vs. DY CIT ,CIRLCE 3(3)(1) , MUMBAI

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ITA 2156/MUM/2026Status: DisposedITAT Mumbai05 May 2026AY 2022-233 pages

In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal noted the assessee's submission regarding the Advance Pricing Agreement covering the assessment year. Consequently, the assessee sought to withdraw the appeal.

What were the facts?

The assessee filed an appeal against the final assessment order concerning transfer pricing adjustments for AY 2022-23. The assessee had entered into a Unilateral Advance Pricing Agreement with the Central Board of Direct Taxes.

What were the issues?

The primary issue was the validity of transfer pricing adjustments in light of a subsequent Advance Pricing Agreement.

Which sections of the Income-tax Act were involved?

Not specified

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “K” MUMBAI

Before: SHRI OM PRAKASH KANT & SHRI ANIKESH BANERJEE

For Appellant: Shri. Bhagirath Ramawat, (SR. DR)
Hearing: 05/05/2026

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “K” MUMBAI

BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI ANIKESH BANERJEE (JUDICIAL MEMBER)

ITA No. 2156/MUM/2026 Assessment Year: 2022-23

Clarivate Analytics (India) Assessment Unit, Income Tax Private Limited, 2nd Floor, Department/ Deputy Vs. Fleet House, Andheri Kurla Commissioner of Income Tax, Road, Gamdevi Road, Marol Circle 3(3)(1), Aayakar Bhawan, Naka, Andheri East, J.B. Maharshi Karve Road, New Nagar S.O., Mumbai – 400059. Marine Lines, Churchgate, Mumbai - 400020 PAN NO. AAFCT 8504 N Appellant Respondent

: Shri Parth Roonhta Assessee by : Shri. Bhagirath Ramawat, (SR. DR) Revenue by

: 28/04/2026 Date of Hearing : 05/05/2026 Date of pronouncement ORDER PER OM PRAKASH KANT, AM

This appeal by the assessee is directed against the final assessment order dated 23.12.2025, passed by the Learned Assessing Officer [in short ‘the Ld. AO’] for Assessment Year (in short ‘A.Y’) 2022-23, pursuant to the direction of the Ld. Dispute Resolution Panel dated 21.11.2025.

Clarivate Analytics (India) Private Limited,, Clarivate Analytics (India) Private Limited, 2 ITA No.2156/MUM/2026

2.

In the present appeal, the assessee has raised multiple In the present appeal, the assessee has raised multiple In the present appeal, the assessee has raised multiple grounds assailing both the validity of the assessment proceedings grounds assailing both the validity of the assessment proceedings grounds assailing both the validity of the assessment proceedings as well as the transfer pricing adjustmen as well as the transfer pricing adjustments made therein. ts made therein.

3.

At the outset, the learned Authorised Signatory appearing on At the outset, the learned Authorised Signatory appearing on At the outset, the learned Authorised Signatory appearing on behalf behalf behalf of of of the the the assessee assessee assessee submitted, submitted, submitted, by by by way way way of of of a a a written written written communication, that the assessee has entered into a Unilateral communication, that the assessee has entered into a Unilateral communication, that the assessee has entered into a Unilateral Advance Pricing Agreement with the Advance Pricing Agreement with the Central Board of Direc Central Board of Direct Taxes on 31.03.2026, which encompasses the assessment year under on 31.03.2026, which encompasses the assessment year under on 31.03.2026, which encompasses the assessment year under consideration. It was submitted that, in view of the said agreement consideration. It was submitted that, in view of the said agreement consideration. It was submitted that, in view of the said agreement covering the transfer pricing issues involved in the present appeal, covering the transfer pricing issues involved in the present appeal, covering the transfer pricing issues involved in the present appeal, the assessee seeks leave to withdraw the appeal. the assessee seeks leave to withdraw the appeal.

4.

Having regard to the aforesaid submission and the request Having regard to the aforesaid submission and the request Having regard to the aforesaid submission and the request made, we find no reason to decline the same. Accordingly, the made, we find no reason to decline the same. Accordingly, the made, we find no reason to decline the same. Accordingly, the appeal filed by the assessee is dismissed as withdrawn. appeal filed by the assessee is dismissed as withdrawn. appeal filed by the assessee is dismissed as withdrawn.

5.

In the result, the appeal of the assessee is dismissed as In the result, the appeal of the assessee is dismissed as In the result, the appeal of the assessee is dismissed as withdrawn.

Order pronounced in the open Court on ounced in the open Court on 05/05 05/2026.

Sd/- Sd/ Sd/- (ANIKESH BANERJEE ANIKESH BANERJEE) (OM PRAKASH KANT OM PRAKASH KANT) JUDICIAL MEMBER JUDICIAL MEMBER ACCOUNTANT MEMBER ACCOUNTANT MEMBER

Mumbai; Dated: 05/05/2026

Clarivate Analytics (India) Private Limited,, Clarivate Analytics (India) Private Limited, 3 ITA No.2156/MUM/2026

M. Ranganath Vittal , Sr. P.S. M. Ranganath Vittal , Sr. P.S.

Copy of the Order forwarded to Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file.

BY ORDER, BY ORDER, //True Copy// (Assistant Registrar) (Assistant Registrar) ITAT, Mumbai ITAT, Mumbai

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