BARCLAYS GLOBAL SERVICE CENTRE PRIVATE LIMITED ,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIR 1(1), PUNE
आयकर अपीलीय अिधकरण ”सी” Ɋायपीठ पुणेमŐ।
IN THE INCOME TAX APPELLATE TRIBUNAL
PUNE BENCHES “C” :: PUNE
BEFORE DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER
AND SHRI VINAY BHAMORE, JUDICIAL MEMBER
आयकर अपील सं. / ITA No.694/PUN/2022
िनधाᭅरण वषᭅ / Assessment Year: 2018-19
Barclays Global Service Centre
Private Limited,
5 to 12 Floor(part), Building
G2 Gera Commerzone SEZ,
Survey No.65, Kharadi,
Vadgaon Sheri, S.O. Pune City,
Pune – 411014. Maharashtra.
V s
The Assistant
Commissioner of Income
Tax,
Circle-1(1), Pune.
PAN: AADCB1173D
Appellant/ Assessee
Respondent / Revenue
Assessee by Shri Riddhi Maru – CA(Virtual)
Revenue by Shri Prakash L Pathade – CIT(DR)
Date of hearing
24/06/2025
Date of pronouncement 24/06/2025
आदेश/ ORDER
PER DR. DIPAK P. RIPOTE, AM:
In this case, Assessee has filed an appeal against the Assessment Order dated 15.07.2022 passed u/s.143(3) r.w.s
144C(13) of the Act, 1961 for the A.Y.2018-19, emanating from order of the Dispute Resolution Panel u/s.144C(5) of the Act, dated
21.06.2022. ITA No.694/PUN/2022 [A]
At the outset, the Assessee filed a letter dated 09.06.2025. The relevant paragraph of the said letter is reproduced here as under : “With respect to the abovementioned APA application, we wish to inform Your Honours that the APA has been signed between the Central Board of Direct Taxes, Department of Revenue, Ministry of Finance, Government of India (CBDT) and the Assessee on 6 February 2025. We have attached the copy of the signed agreement as Annexure 1 for your ready reference.
Basis the above, we wish to submit that since the abovementioned APA agreement signed between the CBDT and the Assessee, covers international transaction of provision of IT support services and ITeS, the Assessee wishes to Suo-moto withdraw the Ground No. 1 of the grounds of appeal (including any sub-grounds) as the said grounds are now covered under APA, Grounds of appeal other than Ground No. 1 of the grounds of appeal (including any sub-grounds) remains status quo and valid for subject matter of appeal. We have attached a copy of the captioned appeal as Annexure 2 for your ready reference”
1 Thus, Assessee intended to withdraw Ground No.1 of the appeal which is related to Transfer Pricing Adjustment. Ld.DR for the Revenue had no objection. Accordingly, we permit to withdraw the Ground No.1 of the Assessee, hence Ground No.1 is dismissed.
Ground No.2 :
Ld.AR submitted that Assessee had filed rectification application before the Assessing Officer with reference to Ground
ITA No.694/PUN/2022 [A]
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No.2 which is related to “Dividend Distribution Tax(DDT) Credit
Not Given”. Ld.AR submitted that the Assessing Officer(AO) has not considered the payment of DDT, though copy of challan was provided. Ld.AR submitted that she has been informed that Assessing Officer has passed a Rectification Order allowing the Credit of Dividend Distribution Tax. In these facts and circumstances of the case, we direct the ld.Assessing Officer to verify the Assessee’s claim of payment of Dividend Distribution
Tax and give credit, if paid. Accordingly, Ground No.2 is allowed for statistical purpose.
Ground No.3:
This Ground is regarding initiation of penalty. This is premature, hence, dismissed.
In the result, appeal of the assessee is Partly allowed for statistical purpose. Order pronounced in the open Court on 24 June, 2025. (VINAY BHAMORE) ACCOUNTANT MEMBER पुणे / Pune; ᳰदनांक / Dated : 24 June, 2025/ SGR
ITA No.694/PUN/2022 [A]
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आदेशकᳱᮧितिलिपअᮕेिषत / Copy of the Order forwarded to :
1. अपीलाथᱮ / The Appellant.
2. ᮧ᭜यथᱮ / The Respondent.
3. The CIT(A), concerned.
4. The Pr. CIT, concerned.
5. िवभागीयᮧितिनिध, आयकर अपीलीय अिधकरण, “सी” बᱶच, पुणे / DR,
ITAT, “C” Bench, Pune.
गाडᭅफ़ाइल / Guard File. आदेशानुसार / BY ORDER,
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Senior Private Secretary
आयकर अपीलीय अिधकरण, पुणे/ITAT, Pune.