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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AI SummaryDismissed

Facts

The 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 received Form 2 for their respective appeals. Consequently, they sought to withdraw the impugned appeals.

Held

The Tribunal noted that the assessees had applied for settlement under the DTVSV scheme and had been issued Form 2. Therefore, the Tribunal treated all three appeals as withdrawn and dismissed them. Liberty was granted to the assessee to apply for recall of the order if the dispute is not settled under DTVSV.

Key Issues

Whether the appeals should be dismissed as withdrawn based on the assessee's application for settlement under the DTVSV scheme.

Sections Cited

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.

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.

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

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 Therefore the appeal of the assessee in IT(IT)A No.50/Bang/2021 is treated as withdrawn and dismissed.

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 Therefore, both these appeals are also treated as withdrawn and hence dismissed.

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.