ENTAIN SOFTWARE DEVELOPMENT SERVICES (INDIA) PRIVATE LIMITED,HYDERABAD V. DCIT, CIRCLE-8(1), HYDERABAD

ITA 1011/HYD/2026

AI Insights

The case involved ENTAIN SOFTWARE DEVELOPMENT SERVICES (INDIA) PRIVATE LIMITED, the appellant, contesting a final assessment order passed by the Assessing Officer under various sections of the Income Tax Act, 1961, related to the assessment year 2022-23. The appeal was directed against the order of the Learned Transfer Pricing Officer and the directions of the Learned Dispute Resolution Panel. However, during the proceedings, the appellant entered into an Advance Pricing Agreement with the CBDT, which resolved the issues pertaining to the international transactions for the relevant assessment years. Consequently, the appellant decided to withdraw the appeal, which was unopposed by the Revenue.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 883867 (ITAT-HYDERABAD)
• Duration Of Justice: 4 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-07-2026
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: DB-B
• Next Hearing Date: 27-07-2026
• Assessment Year: 2022-2023
• Appeal Filed On: 27-03-2026
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Keywords: Transfer pricing; International transaction
• Section: 143(3)

Judgement Text

" आयकर अपीलीय न्यायाधिकरण में, हैदराबाद ‘बी’ बेंच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad “B” Bench, Hyderabad श्री मंजूनाथ जी, माननीय लेखा सदस्य एवं श्री रवीश सूद, माननीय न्याययक सदस्य SHRI G. MANJUNATHA, HON’BLE ACCOUNTANT MEMBER AND SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER ITA 1011/HYD/2026 निर्धारण वर्ा/Assessment Year: 2022-2023) ENTAIN SOFTWARE DEVELOPMENT SERVICES (INDIA) PRIVATE LIMITED HYDERABAD-500032, TELANGANA Vs. DCIT, CIRCLE-8(1) HYDERABAD-500084, TELANGANA अपीलधर्थी Appellant प्रत्यर्थी Respondent Permanent Account Number of Assessee: AADCI6283R अपीलधर्थी द्वारा/Appellant represented by: Ms. Mahima Jain, C.A. प्रत्यर्थी द्वारा/Respondent represented by: Shri Waseem UR Rehman, CIT-DR सुनवाई की तारीख / Date of conclusion of hearing: 27-Jul-2026 घोषणा की तारीख / Date of pronouncement: 27-Jul-2026 Printed from counselvise.com 2 ITA No. 1011/Hyd/2026 आदेश / ORDER PER MANJUNATHA G., A.M : This appeal filed by the assessee is directed against the final assessment order passed by the Assessing Officer under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (in short “the Act”), dated 19.01.2026 pursuant to the order of the Learned Transfer Pricing Officer (in short “Ld. TPO”) under section 92CA(3) of the Act, and the Ld. Dispute Resolution Panel (in short “Ld.DRP”) directions dated 08.12.2025 and pertains to the A.Y. 2022-23. 2. At the time of hearing, the learned counsel for the assessee, Ms. Mahima Jain, C.A., submitted that the assessee seeks to withdraw the present appeal in view of the fact that the assessee has entered into an Advance Pricing Agreement (APA) with the Central Board of Direct Taxes (CBDT) on 27.03.2026, which is applicable for A.Ys. 2022-23 to 2026-27. The learned counsel for the assessee submitted that all the international transactions undertaken by the assessee during the year under consideration are covered by the APA and, therefore, the issues raised in the present appeal stand resolved. Accordingly, the assessee does not wish to pursue the appeal any further and requested that the appeal may be permitted to be withdrawn. 3. The learned CIT-DR for the Revenue, Shri Waseem UR Rehman, raised no objection to the said request. Printed from counselvise.com 3 ITA No. 1011/Hyd/2026 4. We have heard both the parties and considered the request of the assessee. Since the assessee seeks to withdraw the appeal on the ground that all the international transactions involved in the year under consideration are covered by the Advance Pricing Agreement (APA) entered into with the Central Board of Direct Taxes (CBDT), and the issues raised in the appeal stand resolved, and as the Revenue has no objection, we permit the assessee to withdraw the appeal. 5. In the result, the appeal filed by the assessee is dismissed as withdrawn. Order pronounced in the Open Court on 27th July, 2026. Sd/- (श्री रवीश सूद) (RAVISH SOOD) न्याययक सदस्य/JUDICIAL MEMBER Sd/- (मंजूनाथ जी) (MANJUNATHA G.) लेखा सदस्य/ACCOUNTANT MEMBER Sd/- Hyderabad, dated 27.07.2026. TYNM/sps Printed from counselvise.com 4 ITA No. 1011/Hyd/2026 आदेशकी प्रतततिति अग्रेतषत/ Copy of the order forwarded to:- 1. तनर्ााररती/The Assessee : ENTAIN SOFTWARE DEVELOPMENT SERVICES (INDIA) PRIVATE LIMITED, 18TH FLOOR, SKY TWO, PRESTIGE SKY TECH, SURVEY NO.332 (PART) & 333 (PART), PUPPALAGUDA, ISB ROAD, FINANCIAL DISTRICT, HYDERABAD, GACHIBOWLI, K.V. RANGAREDDY, SERI LINGAMPALLY, HYDERABAD-500032, TELANGANA 2. राजस्व/ The Revenue : DCIT, CIRCLE-8(1), O/O DCIT, CIRCLE-8(1), SIGNATURE TOWERS, SY. NO. 6(P) OF KONDAPUR, SY. NO. 37(P) OF KOTHAGUDA,, HYDERABAD-500084, TELANGANA 3. The Principal Commissioner of Income Tax, (IT & TP), Hyderabad. 4. The Disputes Resolution Panel-1, Bangalore 5. तवभागीयप्रतततनतर्, आयकर अिीिीय अतर्करण, हैदराबाद / DR, ITAT, Hyderabad 6. गार्ाफ़ाईि / Guard file आदेशानुसार / BY ORDER Sr. Private Secretary ITAT, Hyderabad Printed from counselvise.com TIRUPATI YAMINI NAGA MALLESWARI Digitally signed by TIRUPATI YAMINI NAGA MALLESWARI Date: 2026.07.31 17:28:11 +05'30' "