SYNAMEDIA LIMITED,UNITED KINGDOM vs. COMMISSIONER OF INCOME TAX, (IT), CIRCLE-1(2), BENGALURU

ITA 3009/BANG/2025Status: DisposedITAT Bangalore31 August 2026AY 2020-218 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the revisionary order passed by the CIT was barred by limitation. Furthermore, the Tribunal found that the assessment order was not erroneous as the AO had made necessary inquiries and taken a plausible view, supported by judicial precedents.

What were the facts?

The Commissioner of Income Tax (CIT) initiated revision proceedings under Section 263 against an assessment order passed by the Assessing Officer (AO). The CIT held the assessment order to be erroneous and prejudicial to the revenue, primarily due to insufficient verification of copyright transfer for software supplied by the assessee, a UK-based company.

What were the issues?

Whether the revisionary order under Section 263 was passed within the prescribed limitation period and whether the original assessment order was erroneous and prejudicial to the interest of the revenue.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 90(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

PER SHRI PRASHANT MAHARISHI, VICE PRESIDENT

1.

Synamedia Ltd. (the assessee/appellant) has filed this appeal in ITA No. 3009/Bang/2025 against the revisionary order dated 9 October 2025 passed under section 263 of the Income-tax Act, 1961 (the Act), by the Commissioner of Income Tax (International Taxation), Bangalore (the learned CIT), for assessment year 2020-21. By that order, the learned CIT held that the ITA 3009/BANG/2025 S

The order continues below.

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