QUINTILES INC.,MUMBAI V. DCIT (IT) CIR 3(3)(1), MUMBAI

ITA 728/MUM/2017

AI Insights

The case involves two appeals by IQVIA RDS Inc. against the orders of the Deputy Commissioner of Income Tax, International Taxation, Mumbai, for the assessment years 2012-13 and 2013-14. The appeals were related to disputes under the Income Tax Act, 1961. The assessee opted to settle these disputes under the Direct Tax Vivad se Vishwas Scheme, 2024, and submitted letters indicating their decision to withdraw the appeals following the settlement. The respondent did not object to the withdrawal. The tribunal, after reviewing the submissions and the certificates issued under the scheme, dismissed the appeals as withdrawn.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 775565 (ITAT-BANGALORE)
• Duration Of Justice: 8 year(s) 7 month(s) 6 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-09-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: C
• Assessment Year: 2013-2014
• Appeal Filed On: 02-02-2017
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: DIVYA K.J.
• Section: 143(3); 92

Judgement Text

"ITA No.2104/Mum/2016 IQVIA RDS Inc., (Formerly known as Quintiles Inc.). Bangalore ITA No.728/Mum/2017 Quintiles Inc., Mumbai IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA No.2104/Mum/2016 Assessment Year: 2012-13 IQVIA RDS Inc. (Formerly known as Quintiles Inc.) 2nd Floor, Etamin Block Prestige Technology Park-II Sarjapur Marathahalli Outer Ring Road Bangalore 560 103 PAN NO : AAACQ2008D Vs. DCIT (Intl. Tax.) Range 3(3)(1) Mumbai APPELLANT RESPONDENT ITA No. 728/Mum/2017 Assessment Year: 2013-14 Quintiles Inc C/o Deloitte Haskins & Sells LLP Indiabulls Finance Centre Tower 3, 30th Floor Elphinstone Mill Compound Elphinstone (W) Mumbai 400 013 PAN NO : AAACQ2008D Vs. DCIT (Intl. Tax.) Range 3(3)(1) Mumbai APPELLANT RESPONDENT Appellant by : NONE Respondent by : Dr. Divya K.J., D.R. Date of Hearing : 08.09.2025 Date of Pronouncement : 09.09.2025 O R D E R PER KESHAV DUBEY, JUDICIAL MEMBER: These two appeals at the instance of the assessee are directed against the orders of the ld. Deputy Commissioner of Income Tax, Printed from counselvise.com ITA No.2104/Mum/2016 IQVIA RDS Inc., (Formerly known as Quintiles Inc.). Bangalore ITA No.728/Mum/2017 Quintiles Inc., Mumbai Page 2 of 3 International Taxation, 3(3)(1), Mumbai vide Order dated 29.01.2016 passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 [ in short “The Act’] for the assessment year 2012-13 and vide order dated 28.11.2016 for the AY 2013-14. 2. The assessee has raised 7 grounds of appeal in ITA No.2104/Mum/2016 and 8 grounds of appeal in ITA No.728/Mum/2017. 3. At the outset, the ld. DR pointed out to the bench that the assessee company had submitted two different letters both dated 17.2.2025 for the assessment years 2012-13 & 2013-14 wherein it is submitted that the assessee had opted to settle the cases under VSVS,2024 and filed the Form 1 DTVSV 2024 for the settlement of the disputes under the Direct Tax Vivad se Vishwas, 2024 and the ld. CIT had issued the Form-2 vide DIN/Acknowledgement No.862180271060225 for the AY 2012-13 & vide DIN/Acknowledgement No.862288181060225 for the AY 2013-14. Further, the assessee had also remitted the amount determined as payable in Form-2 issued for Asst. year 2012-13 & 2013-14 and accordingly, wishes to withdraw both the appeals. 4. Further the Ld. D.R. has no objection for the request of withdrawal of the appeals made by the assessee. 5. We have heard the rival submissions and perused the materials available on record. As per the provisions of section 91(2) of the DTVSV Scheme, 2024, any appeal pending before the ITAT or CIT(A) in respect of disputed interest or disputed penalty or disputed fee or tax arrears shall be deemed to have been withdrawn upon the issuance of certificate u/s 92(1) of the DTVSV Scheme, 2024. Printed from counselvise.com ITA No.2104/Mum/2016 IQVIA RDS Inc., (Formerly known as Quintiles Inc.). Bangalore ITA No.728/Mum/2017 Quintiles Inc., Mumbai Page 3 of 3 5.1 On going through the letters along with the enclosures filed on 17.2.2025, we find that the Form No.2 i.e. Certificates under sub- section (1) of section 92 of the Finance (2) Act, 2024, are issued by the ld. Commissioner of Income Tax on 6.2.2025. Further, the assessee had also remitted the amount determined as payable in Form-2 issued for Asst. year 2012-13 & 2013-14. This Being so, we, as per the request letter dated 17.2.2025 for the assessment years 2012-13 & 2013-14, dismiss these appeals of the assessee as withdrawn with a liberty to reinstate the appeals if the assessee’s applications under the DTVSV Scheme, 2024 are not accepted for any reason. 6. In the result, appeals filed by the assessee are dismissed as withdrawn. Order pronounced in the open court on 9th Sept, 2025 Sd/- (Prashant Maharishi) Vice President Sd/- (Keshav Dubey) Judicial Member Bangalore, Dated 9th Sept, 2025. VG/SPS Copy to: 1. The Applicant 2. The Respondent 3. The CIT 4. The DR, ITAT, Bangalore. 5 Guard file By order Asst. Registrar, ITAT, Bangalore. Printed from counselvise.com "