THE PR COMMISSIONER OF INCOME TAX vs. M/S SOCIETE GENERALE GLOBAL SOLOUTION CENTRE PVT LTD

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ITA/359/2022HC KarnatakaKAHC01033023202225 November 2025Bench: B M SHYAM PRASAD,T.M.NADAF3 pages
AI SummaryDismissed

What did the High Court hold?

The High Court noted the submission regarding the tax effect and disposed of the appeal in light of the circular. The appeal was disposed of based on the monetary limit specified in the circular.

What were the facts?

The appeal was filed by the Revenue against an order of the Income Tax Appellate Tribunal. The Revenue submitted that the tax effect in the appeal would not exceed Rs. 2 Crore, which is the monetary limit stipulated by Circular No. 9/2024.

What were the issues?

The primary issue was whether the appeal should be disposed of based on the tax effect falling below the monetary limit prescribed by a circular. The court considered the monetary limit for appeals as per the relevant circular.

Which sections of the Income-tax Act were involved?

Section 260-A

AI-generated summary — verify with the full judgment below

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HC-KAR NC: 2025:KHC:48678-DB ITA No. 359 of 2022

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 25TH DAY OF NOVEMBER, 2025 PRESENT THE HON'BLE MR. JUSTICE B M SHYAM PRASAD AND THE HON'BLE MR. JUSTICE T.M.NADAF INCOME TAX APPEAL NO. 359 OF 2022

BETWEEN:

1.

THE PR. COMMISSIONER OF INCOME TAX 5TH FLOOR, BMTC BUILDING 80 FEET ROAD KORMANGALA BENGALURU-560095.

2.

THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-12(3) PRESENT ADDRESS ACIT CIRCLE-6(1)(1) 2ND FLOOR, BMTC BUILDING 80 FEET ROAD KORMANGALA BENGALURU-560095.

…APPELLANTS (BY SRI. Y.V. RAVIRAJ A/W SRI. DILIP M, ADVOCATE)

AND:

M/S SOCIETE GENERALE GLOBAL SOLOUTION CENTRE PVT LTD

Digitally signed by REKHA R Location: HIGH COURT OF KARNATAKA

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HC-KAR NC: 2025:KHC:48678-DB ITA No. 359 of 2022

INVENTOR BLDG 6TH FLOOR WHITEFIELD ROAD BENGALURU-560066

…RESPONDENT (BY SRI. TANMAYEE RAJKUMAR.,ADVOCATE)

THIS INCOME TAX APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 29/11/2021 PASSED IN IT(TP)A NO.1188/BANG/2011, FOR THE ASSESSMENT YEAR 2007-2008. PRAYING TO I. FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED ABOVE. II. ALLOW THE APPEAL AND SET ASIDE THE ORDERS PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, BENGALURU IN IT(TP)A NO. 1188/BANG/2011 DATED 29/11/2021 FOR ASSESSMENT YEAR 2007-2008 ANNEXURE-D AND CONFIRM THE ORDER OF THE DRP CONFIRMING THE ORDER PASSED BY THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BENGLAURU.

THIS APPEAL, COMING ON FOR HEARING, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD and HON'BLE MR. JUSTICE T.M.NADAF

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HC-KAR NC: 2025:KHC:48678-DB ITA No. 359 of 2022

ORAL JUDGMENT

(PER: HON'BLE MR. JUSTICE B M SHYAM PRASAD)

Sri Y.V.Raviraj, the learned Senior Standing Counsel for the appellants, submits that the tax effect would not be more than Rs.2 Crore, which is the monetary limit that is contemplated by the Circular No.9/2024 and therefore, the appeal could be disposed of.

In the light of the afore, the appeal stands disposed of.

Sd/- (B M SHYAM PRASAD) JUDGE

Sd/- (T.M.NADAF) JUDGE

SA ct:sr

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