SPRINKLR INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, BENGALURU

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ITTPA 478/BANG/2026Status: DisposedITAT Bangalore05 June 2026AY 2022-232 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal accepted the assessee's request for withdrawal of the appeal, as communicated vide the letter dated 02.06.2026. The reasoning was that the grounds of appeal concerning transfer pricing adjustments were now covered by an Advance Pricing Agreement (APA) entered into by the assessee with the CBDT on 25.03.2026. Consequently, the Tribunal dismissed the present appeal as withdrawn. No specific issue was left undecided, as the appeal was withdrawn by the assessee.

What were the facts?

The assessee, M/s. Sprinklr India Private Limited, filed an appeal against the final assessment order dated 08.12.2025, passed under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act for the assessment year 2022-23. The appeal was filed by the assessee against the order of the DCIT, Circle - 6(1)(1). The amount in dispute is not explicitly stated. The procedural history involves the assessee filing the appeal and subsequently requesting its withdrawal.

What were the issues?

1. Whether the appeal filed by the assessee against the final assessment order for AY 2022-23 should be dismissed as withdrawn, considering the assessee's request based on an Advance Pricing Agreement (APA)? (Question of procedure/fact) Assessee's contention: The assessee, through its learned Authorised Representative, requested the withdrawal of the present appeal. This request was based on a letter dated 02.06.2026, stating that the grounds of appeal pertaining to transfer pricing adjustments are now covered under an APA entered into with the CBDT on 25.03.2026. Revenue's contention: The judgment records no specific argument from the revenue regarding the withdrawal request.

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 IT(TP)A No.: 478/Bang/2026 Assessment Year :2022-23 M/s. Sprinklr India Private Limited 3rd floor, East Wing Building DCIT, Circle - 6(1)(1), No. 3, Block B, Divyashree BMTC Building, 77o Town Centre, Off HAL Vs. Koramangala, Bengaluru Airport Road, Yamlur PO, Bengaluru 560037 PAN: AAQCS9370N APPLICANT RESPONDENT

Assessee by : Sri. Harsha. K.M, CA : Smt. Divya K.J, CIT-DR Revenue by

Date of Hearing : 03-06-2026 Date of Pronouncement : 05-06-2026

ORDER PER SANDEEP SINGH KARHAIL, JUDICIAL MEMBER 1. The assessee has filed thepresent appeal against the impugned final assessment order dated 08.12.2025 passed under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act (“the Act”), for the assessment year 2022-23.

2.

During the hearing, the learned Authorised Representative, by referring to the letter dated 02.06.2026 filed by the assessee, requested the withdrawal of the present appeal on the basis that the grounds of appeal relating to the transfer pricing adjustments are nowcovered under Page 1 of 2

IT(TP)A No.:478/Bang/2026

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

3.

Considering the submissions, the request of the assessee vide letter dated 02.06.2026 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 5th June, 2026.

Sd/- Sd/- (PRASHANT MAHARISHI) (SANDEEP SINGH KARHAIL) VICE PRESIDENT JUDICIAL MEMBER Bangalore, Dated, the 5th 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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