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