M/S. SPRINKLR INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BENGALURU

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ITTPA 1384/BANG/2024Status: DisposedITAT Bangalore08 June 2026AY 2020-212 pages
AI SummaryWithdrawn

What did the Tribunal hold?

The Tribunal accepted the assessee's request for withdrawal of the appeal. The reasoning was based on the assessee's submission that the grounds of appeal, specifically those relating to transfer pricing adjustments, were now covered by the Advance Pricing Agreement (APA) entered into with the CBDT on 25.03.2026. The Tribunal found this submission to be valid and acceded to the request. Consequently, the appeal filed by the assessee was dismissed as withdrawn. No specific findings were made on the merits of the transfer pricing adjustments themselves, as the appeal was disposed of on a procedural basis. The operative direction was to dismiss the appeal as withdrawn.

What were the facts?

The assessee, M/s. Sprinklr India Private Limited, filed an appeal before the Income Tax Appellate Tribunal (ITAT), Bangalore Bench, against the final assessment order dated 24.05.2024. This order was passed under Section 143(3) read with Sections 144C(13) and 144B of the Income Tax Act, 1961, for the assessment year 2020-21. The revenue is represented by the Deputy Commissioner of Income Tax, Circle – 6(1)(1). Subsequently, on 28.05.2026, the assessee requested the withdrawal of its appeal. The reason cited for withdrawal was that the grounds of appeal pertaining to transfer pricing adjustments are now covered by an Advance Pricing Agreement (APA) entered into between the assessee and the CBDT on 25.03.2026.

What were the issues?

1. Whether the grounds of appeal relating to transfer pricing adjustments are covered by the Advance Pricing Agreement (APA) entered into by the assessee with the CBDT. Assessee's contention: The assessee argued that the grounds of appeal concerning transfer pricing adjustments are now rendered moot because they are covered by the APA executed with the CBDT on 25.03.2026. Therefore, the assessee sought to withdraw the appeal. Revenue's contention: The judgment records no specific contention from the revenue regarding the grounds of appeal or the withdrawal request. The revenue's representative was present, but their arguments are not detailed in the provided text.

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: 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.: 1384/Bang/2024 Assessment Year : 2020-21 M/s. Sprinklr India Private Limited 3rd Floor, East Wing Building Deputy Commissioner of No. 3, Block B, Divyashree Income Tax, Circle – 77o Town Centre, Off HAL Vs. 6(1)(1) Airport Road, Yamlur PO, Bengaluru 560037 PAN: AAQCS9370N APPLICANT RESPONDENT

Assessee by : None : Smt. Divya K.J, CIT-DR Revenue by

Date of Hearing : 04-06-2026 Date of Pronouncement : 08-06-2026

ORDER PER SANDEEP SINGH KARHAIL, JUDICIAL MEMBER 1. The assessee has filed a present appeal against the impugned final assessment order dated 24.05.2024 passed under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (“the Act”), for assessment year 2020-21.

2.

The assessee vide its order dated 28.05.2026 sought withdrawal of the present appeal on the basis that the grounds of appeal relating to the transfer pricing adjustments are now covered under the Advance Pricing

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IT(TP)A No.:1384/Bang/2024

Agreement (“APA”) entered into by the assessee with the CBDT on 25.03.2026.

3.

Considering the above, the request of the assessee is accepted and the present appeal is dismissed as withdrawn.

4.

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

Order pronounced in the open court on 8th June, 2026.

Sd/- Sd/- (PRASHANT MAHARISHI) (SANDEEP SINGH KARHAIL) VICE PRESIDENT JUDICIAL MEMBER Bangalore, Dated, the 8th 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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