IQVIA RDS INC. (FORMERLY KNOWN AS QUINTILES INC),BANGALORE V. DCIT (IT) , CIRCLE - 3(3)(1), MUMBAI

ITA 3015/MUM/2018

AI Insights

The case involves IQVIA RDS Inc, formerly known as Quintiles IMS, which appealed against the final assessment order for the Assessment Year 2015-16. The appeal was filed in response to the directions given by the Dispute Resolution Panel (DRP). The assessee opted to settle the dispute under the 'Vivad Se Vishwas Scheme-2024' and submitted the required declarations and payments to the Designated Authority. Consequently, the tribunal dismissed the appeals as withdrawn, allowing for the possibility of restoration if the settlement under the scheme fails.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 473371 (ITAT-MUMBAI)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 12-02-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: I
• Assessment Year: 2015-2016
• Laws Referred To: Income Tax Act
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: KRISHNA KUMAR
• Assessee Lawyers: MANISH AGARWAL

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL, ‘I’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & MS. PADMAVATHY S, ACCOUNTANT MEMBER ITA No.3015/Mum/2018 (Assessment Year :2015-16) & ITA No.3016/Mum/2018 (Assessment Year :2015-16) IQVIA RDS Inc (formerly Quintiles IMS) incorporated as successor to Quintiles Transnational Corp. 2nd Floor, Etamin Block Prestige Technology Park II, Sarajpur-Marathahalli Outer Ring Road, Bangalore-560 103 Vs. The Deputy Commissioner of Income Tax (International Taxation) Circle-3(3)(1), Mumbai PAN/GIR No.AAACQ2008D (Appellant) .. (Respondent) Assessee by Shri Manish Agarwal, Virtually Present Revenue by Shri Krishna Kumar, CIT DR Date of Hearing 11/02/2025 Date of Pronouncement 12/02/2025 आदेश / O R D E R PER BENCH: The aforesaid appeals have been filed by the assessee against final assessment order passed u/s.143(3) r.w.s. 144C(1) for the A.Y.2015-16 passed in pursuance of directions given by the DRP vide order dated 26/02/2018. ITA No.3015/Mum/2018 & ITA No.3016/Mum/2018 M/s. IQVIA INC. (Formerly Quintiles IMS Incorporated as successor to Quintiles Transnational Corp) 2 2. In the aforesaid appeals the ld. Counsel for the assessee has submitted that assessee has opted for settlement of its tax dispute under the ‘Vivad Se Vishwas Scheme-2024’ and has also filed application dated 08/01/2025 before the authorities, the application is reproduced hereunder:- “We refer to the appeal filed by the Appellant for AY 2015-16 before the 'T' Bench of this Hon'ble Tribunal. In this connection, the Appellant submits the following 1. The Appellant has decided to settle the captioned appeal pertaining to AY 2015-16 under the Direct Tax Vivad Se Vishwas Scheme, 2024 ('VSVS'). 2. Accordingly, the Appellant has filed the required declaration and undertaking in Form-1 under the VSVS in respect of the captioned appeal with the Designated Authority ('the DA') on 23 December 2024. A copy of Form-1 filed under the VSVS for AY 2015-16 is enclosed herewith as Annexure 1 for your kind perusal. 3. The DA has issued Form-2, dated 1 January 2025, under the VSVS for the captioned appeal pertaining to AY 2015-16. A copy of Form-2 issued by the DA for AY 2015-16 is enclosed herewith as Annexure 2 4. Further, the Appellant has remitted the amount determined as payable in Form 2 issued for AY 2015-16 (Copy of challan enclosed herewith as Annexure 3) In view of the above, the Appellant wishes to withdraw the captioned appeal for AY 2015-16 pending before your goodself's office.” ITA No.3015/Mum/2018 & ITA No.3016/Mum/2018 M/s. IQVIA INC. (Formerly Quintiles IMS Incorporated as successor to Quintiles Transnational Corp) 3 3. Accordingly, appeals of the assessee are dismissed as withdrawn, however, liberty is given to the assessee in case the application for VSVS does not materialize and is not accepted, assessee may file an application for restoration of the appeal. Accordingly, appeals of the assessee are dismissed in limine. 4. In the result, appeals of the assessee are dismissed. Order pronounced on 12th February,2025. Sd/- (PADMAVATHY S) Sd/- (AMIT SHUKLA) ACCOUNTANT MEMBER JUDICIAL MEMBER Mumbai; Dated 12/02/2025 KARUNA, sr.ps Copy of the Order forwarded to : BY ORDER, (Asstt. Registrar) ITAT, Mumbai 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file. //True Copy// "