IQVIA LTD,UNITED KINGDOM vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION, CIRCLE 1(2), BANGALORE

ITITA 1124/BANG/2023Status: DisposedITAT Bangalore06 January 2025AY 2021-223 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 held that the appeals of both IQVIA Inc. and IQVIA Ltd. were to be treated as withdrawn and dismissed. This decision was based on the assessees' applications for withdrawal, their opting for the Direct Taxes Vivad-se-Vishwas Scheme, 2024, and the subsequent issuance of Form 2 by the Commissioner of Income Tax, Bengaluru. The Tribunal noted that the ld. AR referred to the applications filed by the assessees, and the ld. DR also agreed. In view of the filing of Form 1 under DTVSV 2024 and the consequent issue of Form 2, the appeals were treated as withdrawn and dismissed. However, the assessees were granted liberty to have their appeals revived if the disputes were not resolved under the DTVSV 2024 scheme, subject to the provisions of the Act.

What were the facts?

IQVIA Inc. and IQVIA Ltd. (the assessees) filed appeals before the Income Tax Appellate Tribunal (ITAT) for the assessment year 2021-22. The appeals were filed against an order or action by the Deputy Commissioner of Income Tax, International Taxation, Circle 1(2), Bangalore. The assessees subsequently filed applications for withdrawal of their appeals on 19.12.2023. They stated that they had opted for resolution of the dispute under the Direct Taxes Vivad-se-Vishwas Scheme, 2024 (DTVSV 2024). Necessary declarations were filed, and Form 2 was issued by the CIT, Bengaluru, on 6.12.2024 and 12.12.2024, respectively, confirming their eligibility for the scheme.

What were the issues?

1. Whether the appeals filed by the assessees can be withdrawn in light of their opting for the Direct Taxes Vivad-se-Vishwas Scheme, 2024, and the consequent issuance of Form 2 by the Commissioner of Income Tax. The assessee argued that they had filed applications for withdrawal of their appeals, citing their participation in the DTVSV 2024 scheme. They submitted that necessary declarations were filed and Form 2 was issued by the CIT, Bengaluru, which supported their request for withdrawal. The assessee relied on their applications dated 22.11.2024 and 10.12.2024. The revenue, represented by the CIT(DR), agreed to the withdrawal of the appeals based on the assessees' opting for the DTVSV 2024 scheme and the issuance of Form 2.

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH : BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SOUNDARARAJAN K.

For Respondent: Ms. Nandini Das, CIT(DR)(ITAT), Bengaluru

Hearing: 03.01.2025Pronounced: 06.01.2025

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER IT(IT)A Nos. 1123 & 1124/Bang/2023 Assessment year : 2021-22

IQVIA Inc., Vs. 83, Wooster Heights Road, Danbury Ct 088, The Deputy Commissioner United States of America. of Income Tax, PAN: AADCI 4077P International Taxation, & Cirlce 1(2), IQVIA Ltd., Bangalore. 3, Forbury Place, 23 Forbury Road, Reading, RG1 3JH, United Kingdom. PAN: AAFCI 3079K APPELLANT(S) RESPONDENT

Appellant(s) by : Smt. Manasa Ananthan, Advocate Respondent by : Ms. Nandini Das, CIT(DR)(ITAT), Bengaluru.

Date of hearing : 03.01.2025 Date of Pronouncement : 06.01.2025 O R D E R Per Bench 1. IT(IT)A No. 1123/Bang/2023 is filed by IQVIA Inc. & IT(IT)A No. 1124/Bang/2023 is filed by IQVIA Ltd. (the assessee/appellant) for the assessment year 2021-22. 2. Both the assessees submitted an application for withdrawal of appeal filed on 19.12.2023 as they have opted for resolution of the dispute under the Direct Taxes Vivad-se-Vishwas Scheme, 2024

IT(IT)A Nos. 1123 & 1124/Bang/2023 Page 2 of 3

[DTVSV 2024]. Necessary declarations have been filed and Form 2 by the CIT, Bengaluru is also issued on 6.12.2024 & 12.12.2024. Therefore, assessees wish to withdraw these appeals.

The ld. AR, Smt. Manasa Ananthan, referred to application dated 22.11.2024 & 10.12.2024 filed by both the assessees. The ld. DR also agreed.

In view of filing of Form 1 under DTVSV 2024 on 22.11.2024 and 10.12.2024 by both the assessees and consequent issue of Form 2 by the CIT, Bengaluru dated 06.12.2024 & 12.12.2024 respectively, the appeals of the assessee are treated as withdrawn and hence dismissed.

However, the assessees are given liberty that in case disputes are not resolved under the DTVSV 2024 on application filed by the assessees, the appeals of the assessees would be revived recalling this order, subject to the provisions of the Act.

In the result, both the appeals of the assessees are treated as dismissed as withdrawn.

Pronounced in the open court on this 06th day of January, 2025. Sd/- Sd/- ( SOUNDARARAJAN K.) ( PRASHANT MAHARISHI ) JUDICIAL MEMBER VICE PRESIDENT Bangalore, Dated, the 06th January, 2025. /Desai S Murthy /

IT(IT)A Nos. 1123 & 1124/Bang/2023 Page 3 of 3

Copy to:

Appellant(s) 2. Respondent 3. Pr. CIT 4. CIT(A) 5. DR, ITAT, Bangalore.

By order

Assistant Registrar ITAT, Bangalore.

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