SIGNANT HEALTH PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1) , HYDERABAD

ITA 673/HYD/2026Status: DisposedITAT Hyderabad06 October 2026AY 2022-235 pages
AI SummaryWithdrawn

What did the Tribunal hold?

The Tribunal noted that the assessee had filed a letter dated 05.10.2026 for withdrawal of the appeal. The assessee's authorized representative submitted that the Assessing Officer had passed a rectification order under section 154 of the Income Tax Act, 1961, which allowed the assessee's claim, leaving no grievance. Consequently, the assessee requested to withdraw the appeal. The revenue's representative raised no objection. The Tribunal found that the rectification order by the Assessing Officer rendered the appeal infructuous. Therefore, the appeal was allowed to be withdrawn. The operative direction was to dismiss the appeal as withdrawn. No specific issue was left undecided, as the appeal was disposed of on procedural grounds.

What were the facts?

The assessee, SIGNANT HEALTH PRIVATE LIMITED, filed an appeal against the order dated 19.12.2025 of the learned Assessment Unit, Income Tax Department for the assessment year 2022-2023. The appeal challenged the transfer pricing adjustment, interest on demand, and initiation of penalty proceedings. Subsequently, the assessee filed a letter on 05.10.2026 seeking to withdraw the appeal. The assessee's representative stated that a rectification order under section 154 of the Income Tax Act, 1961, had been passed by the Assessing Officer, resolving the assessee's grievance. The revenue representative raised no objection to the withdrawal.

What were the issues?

1. Whether the Transfer Pricing Officer (TPO) erred in computing an adjustment under section 92CA of the Income Tax Act, 1961, when the profit-linked margin of the assessee fell within the arm's length range as per the binding directions of the Dispute Resolution Panel (DRP)? (Assessee's contention: The TPO erred by not considering the corrigendum order to the Transfer Pricing order, which gave effect to the DRP's directions and deleted the entire TP adjustment. The final assessment order failed to consider this corrigendum, leading to an incorrect adjustment). 2. Whether the Assessing Officer erred in computing demand under section 156 of the Act, and if interest under section 234D needs recomputation based on the Tribunal's decision on the first ground? (Assessee's contention: Interest under section 234D is consequential and should be recomputed). 3. Whether the Assessing Officer erred in initiating penalty proceedings under Section 270A of the Act for underreporting of income, which was a consequence of misreporting of income? (Assessee's contention: Penalty proceedings were wrongly initiated). The revenue did not record any specific arguments on these grounds as the appeal was withdrawn.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 156,Section 234D,Section 270A,Section 154,Section 143(3),Section 144C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, HYDERABAD

Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G.

For Respondent: DR Seema Meena
Pronounced: 06.10.2026

PER VIJAY PAL RAO, VICE PRESIDENT:

This appeal by the Assessee is directed against the Order dated 19.12.2025 of the learned Assessment Unit, Income Tax Department for the assessment year 2022-2023. 2. The Assessee has raised the following grounds of appeal:

“Ground 1: Not considering the corrigendum order to the 1) Transf

The order continues below.

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