XLHEALTH CORPORATION INDIA PRIVATE LIMITED,BANGALORE, KARNATAKA vs. DCIT, CIRCLE - 7(1)(1), , BENGALURU, KARNATAKA

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ITA 2063/BANG/2024Status: DisposedITAT Bangalore04 June 2026AY 2021-222 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal considered the assessee's request for withdrawal based on the BAPA. The grounds of appeal were covered under the BAPA.

What were the facts?

The assessee filed an appeal against the final assessment order for AY 2021-22. The assessee later submitted that they had entered into a Bilateral Advance Pricing Agreement (BAPA) with the CBDT.

What were the issues?

Whether the appeal should be withdrawn as the transfer pricing issues are covered under a BAPA. The impact of a BAPA on pending appeals.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH : BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SANDEEP SINGH KARHAIL

For Appellant: CA : Smt. Divya K.J, CIT-DR

IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT & SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA No.: 2063/Bang/2024 Assessment Year : 2021-22 XLHealth Corporation India Private Limited 3rd floor, North Tower Deputy Commissioner of No.18, ITC Green Centre, Income-tax, Circle – ITC Limited, Banaswadi Vs. 7(1)(1), Bengaluru Main Road, Maruthiseva Nagar, Bangalore, Karnataka 560005 PAN: AAACX0544K APPLICANT RESPONDENT

Assessee by : Sri. Chavalli Narayan, CA : Smt. Divya K.J, CIT-DR Revenue by

Date of Hearing : 01-06-2026 Date of Pronouncement : 04-06-2026

ORDER PER SANDEEP SINGH KARHAIL, JUDICIAL MEMBER

1.

The assessee has filed the present appeal against the impugned final assessment order dated 20.08.2024 passed under section 143(3) read with section 144C(13) read with section 144B of the Income Tax Act, 1961 (“the Act”) for the assessment year 2021-22.

2.

During the hearing, the Ld. Authorized Representative by referring to the letter dated 06.04.2026 filed by the assessee submitted that the

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ITA No.:2063/Bang/2024 assessee has entered into Bilateral Advance Pricing Agreement (“BAPA”) with the CBDT and accordingly requested for withdrawal of the present appeal on the basis that the grounds of appeal relating to the Transfer Pricing Adjustment in respect of International Transaction of provision of IT and ITeS, notional interest on outstanding receivables and notional interest on unbilled revenue are covered under the BAPA entered by the assessee with the CBDT on 24.03.2026.

3.

Considering the request made by the assessee, the present appeal is dismissed as withdrawn.

4.

In the result, the appeal by the assessee is dismissed as withdrawn. Order pronounced in the open court on 4th June, 2026.

Sd/- Sd/- (PRASHANT MAHARISHI) (SANDEEP SINGH KARHAIL) VICE PRESIDENT JUDICIAL MEMBER Bangalore, Dated, the 4th June, 2026. *VM* Copy to: 1. Appellant 2. Respondent 3. CIT 4. DR, ITAT, Bangalore 5. CIT(A) By order

Assistant Registrar, ITAT, Bangalore

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