M/S KARNATAKA STATE vs. THE DEPUTY DIRECTOR OF INCOME TAX

PDF · subscribers
ITA/91/2022HC KarnatakaKAHC01041781202116 July 2025Bench: S.G.PANDIT,T.M.NADAF2 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court of Karnataka considered the memo filed by the appellant, M/s. Karnataka State Cricket Association, seeking to withdraw the appeal. The memo stated that the dispute had been settled under the Direct Tax Vivad Se Vishwas Act, 2020, and requested liberty to revive the appeal if the settlement was not finalized. The Court noted that the memo was placed on record. Accordingly, the Tribunal held that the appeal is dismissed as withdrawn with the liberty as sought by the appellant. No decision was made on the merits of the original dispute.

What were the facts?

The appellant, M/s. Karnataka State Cricket Association, filed an appeal before the High Court of Karnataka against an order dated June 14, 2021, passed by the Income Tax Appellate Tribunal (ITAT), Bangalore Bench, in ITA No. 64/Bang/2015 for the Assessment Year 2010-11. The appeal was filed under Section 260-A of the Income Tax Act, 1961. The respondent was the Deputy Director of Income Tax (Exemptions) Circle-17(2). Subsequently, the appellant filed a memo on July 11, 2025, seeking to withdraw the appeal. The reason for withdrawal was that the dispute had been settled under the Direct Tax Vivad Se Vishwas Act, 2020, with a liberty to revive the appeal if the settlement was not finalized.

What were the issues?

1. Whether the appeal can be withdrawn by the appellant due to settlement under the Direct Tax Vivad Se Vishwas Act, 2020, with liberty to revive? Assessee's Contention: The assessee, M/s. Karnataka State Cricket Association, contended that the dispute has been settled under the Direct Tax Vivad Se Vishwas Act, 2020. They filed a memo seeking leave to withdraw the appeal with liberty to revive it if the settlement under the Act is not successful. The assessee relied on the provisions of the Direct Tax Vivad Se Vishwas Act, 2020, which provides for a mechanism to settle tax disputes. Revenue's Contention: The judgment does not record any specific contention from the revenue regarding the withdrawal of the appeal. However, the memo filed by the appellant was placed on record, indicating the revenue's implicit acceptance of the procedure.

Which sections of the Income-tax Act were involved?

Section 260-A

AI-generated summary — verify with the full judgment below

- 1 -

HC-KAR NC: 2025:KHC:26173-DB ITA No. 91 of 2022 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 16TH DAY OF JULY, 2025 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE T.M.NADAF INCOME TAX APPEAL NO.91 OF 2022 BETWEEN: M/S. KARNATAKA STATE CRICKET ASSOCIATION, M.CHINNASWAMY STADIUM, MAHATMA GANDHI ROAD, BENGALURU-560001. PAN: AAATT2540E …APPELLANT (BY SRI. ANNAMALAI.S., & M.LAVA, ADVOCATES) AND: THE DEPUTY DIRECTOR OF INCOME TAX (EXEMPTIONS) CIRCLE-17(2) C.R.BUILDING, QUEENS ROAD, BENGALURU-560001. …RESPONDENT (BY SRI. M.DILIP, ADVOCATE)

THE INCOME TAX APPEAL IS FILED UNDER SECTION 260- A OF INCOME TAX ACT, 1961, ARISING OUT OF ORDER DATED 14/6/2021 PASSED IN ITA NO.64/BANG/2015 FOR A.Y. 2010- 11, PRAYING TO FORMULATE THE SUBSTANTIAL QUESTION OF LAW AS STATED ABOVE AND ANSWER THE SAME IN FAVOUR OF THE APPELLANT AND ETC. THIS APPEAL, COMING ON FOR HEARING, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: Digitally signed by SHARADAVANI B Location: High Court of Karnataka

- 2 -

HC-KAR NC: 2025:KHC:26173-DB ITA No. 91 of 2022 CORAM: HON'BLE MR. JUSTICE S.G.PANDIT and HON'BLE MR. JUSTICE T.M.NADAF ORAL JUDGMENT (PER: HON'BLE MR. JUSTICE S.G.PANDIT)

Memo dated 11.07.2025 is filed by the appellant, seeking leave to withdraw the appeal stating that the dispute is settled under the Direct Tax Vivad Se Vishwas Act, 2020 (for short 'the Act'), with liberty to revive the appeal in case the dispute is not settled under the Act. 2. Memo is placed on record. 3. Accordingly, appeal is dismissed as withdrawn with liberty as sought. Sd/- (S.G.PANDIT) JUDGE Sd/- (T.M.NADAF) JUDGE SMJ List No.: 1 Sl No.: 1

More judgments on Section 260-A

All 2,570 judgments and leading authorities on Section 260-A →

Recent GST High Court judgments

Search GST case law →