ATLASSIAN INDIA LLP,BENGALURU vs. ASSESSMENT UNIT, BENGALURU

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ITA 325/BANG/2026Status: DisposedITAT Bangalore04 June 2026AY 2022-232 pages
AI SummaryDismissed

What did the Tribunal hold?

The assessee requested to withdraw the appeal as the issue was covered by a Unilateral Advance Pricing Arrangement (UAPA) entered into with the CBDT. The Tribunal accepted the request and dismissed the appeal.

What were the facts?

The assessee filed an appeal against the final assessment order for AY 2022-23. The appeal concerned transfer pricing adjustments for software development and support services.

What were the issues?

Whether the appeal should be withdrawn due to a subsequent UAPA agreement covering the disputed transfer pricing adjustments.

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: Ms. Divya Motwani, 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 IT(TP)A No.: 325/Bang/2026 Assessment Year : 2022-23 Assessment Unit, Income M/s. Atlassian India LLP Tax Department and 5th Floor, Divyasree Greens, DC/ACIT TP-1(1)(1), 4th, Intermediate Ring Road, Bengalore, BMTC Building, Challaghatta Village, Vs. 80 Feet Road, Koramangala Domlur, Bengaluru, 560071 Bangalore PAN: ABKFA6464H APPLICANT RESPONDENT

Assessee by : Ms. Divya Motwani, 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 26.11.2025 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 2022-23.

2.

During the hearing, the Ld. Authorized Representative (“Ld. AR”) by referring to the letter dated 07.04.2026 filed by the assessee requested for withdrawal of the present appeal on the basis that grounds of appeal relating to the Transfer Pricing Adjustments in respect of International Transactions pertaining to provision of Software Development and Support Page 1 of 2

IT(TP)A No.:325/Bang/2026

Services is now covered under the Unilateral Advance Pricing Adjustment (“UAPA”) entered into by the assessee with the CBDT on 30.03.2026.

3.

Considering the submissions, the request of the assessee vide order dated 07.04.2026 is accepted, and 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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