QUINTILES TRANSNATIONAL CORPORATION,MUMBAI V. DDIT (IT) RG 4(2), MUMBAI

ITA 567/MUM/2013

AI Insights

The case involves multiple appeals by various assessees against the orders passed by the Commissioner of Income Tax (Appeals), Mumbai. The assessees, including IQVIA Inc and IQVIA RDS Inc, were involved in disputes concerning the assessment years 2008-09 to 2014-15. These disputes were related to international transactions and were under the scrutiny of the Dy. Director of Income Tax (Intl. Transaction), Mumbai. The assessees decided to settle their disputes under the Direct Tax Vivad Se Vishwas Scheme, 2024, and filed Form-2 as prescribed under the scheme. Consequently, they requested the withdrawal of all appeals, which was confirmed by the Learned Departmental Representative (DR) without any objection.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 41303 (ITAT-BANGALORE)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 05-03-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: C
• Assessment Year: 2008-2009
• Laws Referred To: Direct Tax Vivad se Vishwas Scheme (DTVSV), 2024
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: NEERA MALHOTRA
• Assessee Lawyers: DHIRAJ
• Keywords: Competent authority

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER SN ITA No. Asst. Year PAN No. Assessee Revenue 1 567/Mum/2013 2008-09 AAACQ 2015 N IQVIA Inc (Formerly known as Quintiles IMS Incorporated as successor to Quintiles Transactions Corp.) 2nd Floor, Etamin Block, Prestige Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 Dy. Director of Income Tax (Intl. Transaction), Range-4(2), Mumbai. 2 568/Mum/2013 2009-10 AAACQ 2015 N IQVIA Inc (Formerly known as Quintiles IMS Incorporated as successor to Quintiles Transactions Corp.) 2nd Floor, Etamin Block, Prestige Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 Dy. Director of Income Tax (Intl. Transaction), Range-4(2), Mumbai 3 569/Mum/2013 2008-09 AAACQ 2008 D IQVIA RDS Inc (Formerly known as Quntiles Inc.) 2nd Floor, Etamin Block, Prestige Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 Dy. Director of Income Tax (Intl. Transaction), Range-4(2), Mumbai 4 570/Mum/2013 2009-10 AAACQ 2008 D IQVIA RDS Inc (Formerly known as Quintiles Inc.) 2nd Floor, Etamin Block, Prestige Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 Dy. Director of Income Tax (Intl. Transaction), Range-4(2), Mumbai 5 1149/Mum/2014 2010-11 AAACQ 2015 N IQVIA RDS Inc (Formerly known as Quntiles Inc.) 2nd Floor, Etamin Block, Prestige Dy. Director of Income ITA No.569 & others/Mum/2013 & Ors. S.P Nos.304 & Ors./Mum/2017 Page 2 of 7 . Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 Tax (Intl. Transaction), Range-4(2), Mumbai 6 469/Mum/2015 2011-12 AAACQ 2015 N IQVIA Inc (Formerly known as Quintiles IMS Incorporated as successor to Quintiles Transactions Corp.) 2nd Floor, Etamin Block, Prestige Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 Dy. Director of Income Tax (Intl. Transaction), Range-4(2), Mumbai 7 470/Mum/2015 2011-12 AAACQ 2015 N Quintiles Inc C/o Deloitte Haskins & Sells LLP, Indiabulls Finance Center, Tower – 3, 30th Floor, Elphinstone Mill Compound Elphinstone (W), Mumbai-400 013 Dy. Director of Income Tax (Intl. Transaction), Range-4(2), Mumbai. 8 3109/Mum/2015 2008-09 AAACQ 2015 N IQVIA Inc (Formerly known as Quintiles IMS Incorporated as successor to Quintiles Transactions Corp.) 2nd Floor, Etamin Block, Prestige Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 Dy. Director of Income Tax (Intl. Transaction), Range-4(2), Mumbai 9 3110/Mum/2015 2008-09 AAACQ 2008 D IQVIA RDS Inc (Formerly known as Quintiles Inc.) 2nd Floor, Etamin Block, Prestige Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 The Dy. Director of Income Tax, (International Taxation) – Range – 4(2), Mumbai 10 3111/Mum/2015 2009-10 AAACQ 2008 D IQVIA RDS Inc (Formerly known as Quintiles Inc.) 2nd Floor, Etamin Block, Prestige Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 “ Dy. Director of Income Tax (Intl. Transaction), Range-4(2), Mumbai ITA No.569 & others/Mum/2013 & Ors. S.P Nos.304 & Ors./Mum/2017 Page 3 of 7 . 11 3112/Mum/2015 2009-10 AAACQ 2015 N IQVIA Inc (Formerly known as Quintiles IMS Incorporated as successor to Quintiles Transactions Corp.) 2nd Floor, Etamin Block, Prestige Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 The Dy. Director of Income Tax, (International Taxation) – Range – 4(2), Mumbai. 12 1148/Mum/2014 2010-11 AAACQ 2015 N IQVIA Inc (Formerly known as Quintiles IMS Incorporated as successor to Quintiles Transactions Corp.) 2nd Floor, Etamin Block, Prestige Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 Dy. Director of Income Tax (Intl. Transaction), Range-4(2), Mumbai 13 2105/Mum/2016 2012-13 AAACQ 2015 N IQVIA Inc (Formerly known as Quintiles IMS Incorporated as successor to Quintiles Transactions Corp.) 2nd Floor, Etamin Block, Prestige Technology Park-II, Sarjapur – Marathahalli Outer Ring Road, Bangalore – 560 103 Dy. Director of Income Tax (Intl. Transaction), Circle-3(3)(1), Mumbai. 14 727/Mum/2017 2013-14 AAACQ 2015 N Quintiles Transactional Corp. C/o Deloitte Haskins & Sells LLP, Indiabulls Finance Center, Tower – 3, 30th Floor, Elphinstone Mill Compound Elphinstone (W), Mumbai-400 013 Dy. Director of Income Tax (Intl. Transaction), Circle-3(3)(1), Mumbai 15 7191/Mum/2017 2014-15 AAACQ 2008 D Quintiles Inc C/o Deloitte Haskins & Sells LLP, Indiabulls Finance Center, Tower – 3, 30th Floor, Elphinstone Mill Compound Elphinstone (W), Mumbai-400 013 Dy. Director of Income Tax (Intl. Transaction), Circle-3(3)(1), Mumbai 16 7192/Mum/2017 2014-15 AADCI 4077 P Quintiles IMS Incorporated (as successor to Quintiles Transactional Corp. C/o Deloitte Haskins & Sells LLP, Indiabulls Finance Center, Dy. Director of Income Tax (Intl. Transaction), ITA No.569 & others/Mum/2013 & Ors. S.P Nos.304 & Ors./Mum/2017 Page 4 of 7 . Tower – 3, 30th Floor, Elphinstone Mill Compound Elphinstone (W), Mumbai-400 013 Circle-3(3)(1), Mumbai SN S.P No. Asst. Year PAN No. Assessee Revenue 1 304/Mum/2017 3110/Mum/2015 2008-09 AAACQ 2008 D Quintiles Inc C/o Deloitte Haskins & Sells LLP Anchorage II, 100/2, Richmond Road, Bangalore – 560 025 Dy. Director of Income Tax (Intl. Transaction), Circle-3(3)(1), Mumbai. 2 305/Mum/2017 3111/Mum/2015 2009-10 AAACQ 2015 N “ “ 3 306/Mum/2017 3109/Mum/2015 2008-09 AADCI 4077 P Quintiles IMS Incorporated (as successor to Quintiles Transactional Corp) C/o Deloitte Haskins & Sells LLP Anchorage II, 100/2, Richmond Road, Bangalore – 560 025 “ 4 307/Mum/2017 3112/Mum/2015 2009-10 AADCI 4077 P “ “ Assessee by : Shri Dhiraj, CA Revenue by : Ms. Neera Malhotra, CIT (DR) Date of hearing : 29.01.2025 Date of Pronouncement : 04.03.2025 ITA No.569 & others/Mum/2013 & Ors. S.P Nos.304 & Ors./Mum/2017 Page 5 of 7 . O R D E R PER BENCH: All the above captioned appeals are by the assessee against the order passed by the Commissioner of Income Tax (Appeals), Mumbai. The assessees have also filed stay petitions. 2. In all the present appeals, all the assessees have contended that they intend to settle the dispute under the Vivad Se Vishwas (VSV) Scheme 2024 introduced by the Government of India. Accordingly, at the outset, during the course of the proceedings before us, the ld. Authorized Representative (AR) submitted that all the assessees are in the process of settling the tax dispute in the appeals on hand and filed Form-2, on behalf of all the assessee, as prescribed under Direct Tax Vivad se Vishwas Scheme (DTVSV), 2024, issued by the Competent Authority in support of his contention. Accordingly, the ld. AR filed the letter requesting for the withdrawal of all the captioned appeals of different assessees. 3. The Learned Departmental Representative (DR) confirmed the submission of the ld. AR and raised no objection to the dismissal of the appeals in light of the settlement of dispute under DTVSV, 2024. 4. Considering the submission of the parties and in view of the fact that Form-2 has been issued by the revenue authority, we find that no purpose would be served by keeping these appeals pending before the ITA No.569 & others/Mum/2013 & Ors. S.P Nos.304 & Ors./Mum/2017 Page 6 of 7 . Tribunal. Accordingly, these appeals are dismissed as the issue is being resolved under Direct Tax Vivad se Vishwas Scheme, 2024. 4.1 However, before parting it is clarified that in the event the Competent Authority under DTVSV, 2024, for any reason, deems the settlement to be non-operative or invalid, the different assessee shall be at liberty to approach the Tribunal by filing a suitable application for restoration of the appeals to its/ their original numbers as per the provisions of law. 5. In the result, all the appeals filed by different Assessee are hereby dismissed under DTVSV 2024. S.P. Nos. 304 - 307/Mum/2017 6. The assessees have also filed above captioned stay petitions. Since, the appeals of the assessees are dismissed, these stay petitions becomes infructuous and hence accordingly dismissed as infructuous. 7. In the result, all the stay petitions are dismissed as infructuous. Order pronounced in court on 5th day of March, 2025 Sd/- Sd/- (KESHAV DUBEY) (WASEEM AHMED) Judicial Member Accountant Member Bangalore Dated, 5th March, 2025 / vms / ITA No.569 & others/Mum/2013 & Ors. S.P Nos.304 & Ors./Mum/2017 Page 7 of 7 . Copy to: 1. The Applicant 2. The Respondent 3. The CIT 4. The CIT(A) 5. The DR, ITAT, Bangalore. 6. Guard file By order Asst. Registrar, ITAT, Bangalore "