IQVIA RDS INC (EARLIER KNOWN AS QUINTILES INC),BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-2(2), BANGALORE

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ITA 10/BANG/2021Status: DisposedITAT Bangalore15 January 2025AY 2016-17Bench: SHRI PRASHANT MAHARISHI (Vice President), SHRI SOUNDARARAJAN K., JUDICIAL MEMBER IT(IT)A Nos.10, 11 & 50/Bang/2021 Assessment years : 2016-17, 2017-18 & 2017-18 | IQVIA RDS Inc. | [earlier Quintiles Inc.] | PAN: AAACQ 2008D | & | IQVIA Inc. | [earlier Quintiles IMS | successor to Quintiles | Transnational Corp] | PAN: AADCI 4077P | Omega Embassy Techsquare, | Marathahalli-Sarjapur Outer | Ring Road, | Kadubeesanahalli, | Bengaluru - 560 103. | APPELLANT(S) | Vs. The Deputy Commissioner | of1 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 noted that the assessees wished to withdraw the impugned appeals in light of the DTVSV settlement and Form 2 issuance. Consequently, all three appeals were treated as withdrawn and dismissed.

What were the facts?

Three appeals were filed by IQVIA RDS Inc. and IQVIA Inc. for Assessment Years 2016-17 and 2017-18. The assessees applied for settlement under the Direct Tax Vivad Se Vishwas Scheme, 2024 (DTVSV) and were issued Form 2.

What were the issues?

Whether the appeals should be dismissed as withdrawn due to the assessee applying for settlement under the Direct Tax Vivad Se Vishwas Scheme, 2024.

Which sections of the Income-tax Act were involved?

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH : BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SOUNDARARAJAN K.

For Appellant: Shri Dhiraj, Advocate
For Respondent: Smt. Nandini Das, CIT(DR)(ITAT), Bengaluru
Hearing: 10.01.2025Pronounced: 15.01.2025

O R D E R Per Bench 1. IT(IT)A Nos.10 & 11/Bang/2021 are filed by IQVIA RDS Inc. for AYs 2016-17 & 2017-18 and IT(IT)A No.50/Bang/2021 is filed by IQVIA Inc. for the AY 2017-18 respectively.

2.

These appeals are fixed for hearing at the request of the assessee today as assessee has applied for settlement under the Direct Tax Vivad Se Vishwas Scheme, 2024 [DTVSV] and where Form 2 has also been issued and therefore the assessees in all these 3 appeals would like to withdraw the impugned appeals.

3.

The ld. AR reiterated the same facts. The ld. DR also agreed.

4.

On perusal of the application dated 04.12.2024 wherein we find that in IT(IT)A No.50/Bang/2021 IQVIA Inc. has been issued Form 2 dated 13.12.2024 under DTVSV 2024 for settlement of the impugned appeal. Therefore the appeal of the assessee in IT(IT)A No.50/Bang/2021 is treated as withdrawn and dismissed.

5.

IT(IT)A Nos.10 & 11/Bang/2021 for AYs 2016-17 & 2017-18 IQVIA RDS Inc. has also been issued Form 2 on 12.12.2024 & 17.12.2024 respectively. Therefore, both these appeals are also treated as withdrawn and hence dismissed.

6.

The assessee is given liberty that in case if the dispute is not settled under DTVSV, application may be made for recall of this order in accordance with law.

IT(IT)A Nos.10, 11 & 50/Bang/2021 Page 3 of 3

7.

In the result, all the above 3 appeals are dismissed as withdrawn.

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