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Facts
The assessee had filed two appeals for assessment years 2012-13 and 2013-14 against orders of the DCIT. The assessee subsequently opted to settle the cases under the Direct Tax Vivad se Vishwas Scheme, 2024, and paid the determined amounts.
Held
The Tribunal noted that the assessee had opted for settlement under the Vivad se Vishwas Scheme and had remitted the amounts. As per the scheme's provisions, pending appeals are deemed withdrawn upon certificate issuance.
Key Issues
Whether the appeals are to be dismissed as withdrawn in light of the assessee opting for settlement under the Vivad se Vishwas Scheme, 2024, and payment of dues.
Sections Cited
143(3), 144C(13), 91(2), 92(1)
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Income Tax Appellate Tribunal, “C’’ BENCH: BANGALORE
Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY
PER KESHAV DUBEY, JUDICIAL MEMBER:
These two appeals at the instance of the assessee are directed against the orders of the ld. Deputy Commissioner of Income Tax, IQVIA RDS Inc., (Formerly known as Quintiles Inc.). Bangalore Quintiles Inc., Mumbai Page 2 of 3 International Taxation, 3(3)(1), Mumbai vide Order dated 29.01.2016 passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 [ in short “The Act’] for the assessment year 2012-13 and vide order dated 28.11.2016 for the AY 2013-14.
At the outset, the ld. DR pointed out to the bench that the assessee company had submitted two different letters both dated 17.2.2025 for the assessment years 2012-13 & 2013-14 wherein it is submitted that the assessee had opted to settle the cases under VSVS,2024 and filed the Form 1 DTVSV 2024 for the settlement of the disputes under the Direct Tax Vivad se Vishwas, 2024 and the ld. CIT had issued the Form-2 vide DIN/Acknowledgement No.862180271060225 for the AY 2012-13 & vide DIN/Acknowledgement No.862288181060225 for the AY 2013-14. Further, the assessee had also remitted the amount determined as payable in Form-2 issued for Asst. year 2012-13 & 2013-14 and accordingly, wishes to withdraw both the appeals.
Further the Ld. D.R. has no objection for the request of withdrawal of the appeals made by the assessee.
We have heard the rival submissions and perused the materials available on record. As per the provisions of section 91(2) of the DTVSV Scheme, 2024, any appeal pending before the ITAT or CIT(A) in respect of disputed interest or disputed penalty or disputed fee or tax arrears shall be deemed to have been withdrawn upon the issuance of certificate u/s 92(1) of the DTVSV Scheme, 2024.
5.1 On going through the letters along with the enclosures filed on 17.2.2025, we find that the Form No.2 i.e. Certificates under sub- section (1) of section 92 of the Finance (2) Act, 2024, are issued by the ld. Commissioner of Income Tax on 6.2.2025. Further, the assessee had also remitted the amount determined as payable in Form-2 issued for Asst. year 2012-13 & 2013-14. This Being so, we, as per the request letter dated 17.2.2025 for the assessment years 2012-13 & 2013-14, dismiss these appeals of the assessee as withdrawn with a liberty to reinstate the appeals if the assessee’s applications under the DTVSV Scheme, 2024 are not accepted for any reason.
In the result, appeals filed by the assessee are dismissed as withdrawn.
Order pronounced in the open court on 9th Sept, 2025