THE PR. COMMISSIONER OF INCOME TAX, vs. M/S TEXAS INSTRUMENTS (INDIA) PVT. LTD.,

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ITA/177/2023HC KarnatakaKAHC01017372202310 September 2025Bench: S.G.PANDIT,K. V. ARAVIND3 pages
AI SummaryDismissed

What did the High Court hold?

The High Court dismissed the appeal as not maintainable due to the tax effect being below the enhanced monetary limit. Liberty was granted to the appellants to seek revival if exceptions were made out.

What were the facts?

The Income Tax Department filed an appeal before the High Court against an order of the Income Tax Appellate Tribunal. The tax effect in the appeal was Rs. 50,37,051/-. The Ministry of Finance had subsequently enhanced the monetary limit for filing appeals before the High Court to Rs. 2,00,00,000/-.

What were the issues?

Whether the appeal filed by the Revenue is maintainable before the High Court considering the revised monetary limits for filing appeals.

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:35636-DB ITA No. 177 of 2023

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 10TH DAY OF SEPTEMBER, 2025 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND INCOME TAX APPEAL No. 177 OF 2023 BETWEEN:

1.

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

2.

THE JOINT COMMISSIONER OF INCOME TAX, LTU, PRESENT ADDRESS: DCIT, CIRCLE-7(1)(1), 2ND FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU - 560095. …APPELLANTS (BY SRI DILIP M., STANDING COUNSEL) AND:

1.

M/S TEXAS INSTRUMENTS (INDIA) PVT. LTD., BAGMANE TECH PARK, No.66/3, ADJACENT TO LRDE, BYRASANDRA, C V RAMAN NAGAR, BENGALURU - 560093. PAN. AAACT 5445M …RESPONDENT (BY SRI P.D. ANKUR, ADVOCATE)

Digitally signed by VALLI MARIMUTHU Location: HIGH COURT OF KARNATAKA

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HC-KAR NC: 2025:KHC:35636-DB ITA No. 177 of 2023

THIS ITA / INCOME TAX APPEAL IS FILED UNDER SECTION 260-A OF THE INCOME TAX ACT, 1961, PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED ABOVE, ALLOW THE APPEAL AND SET ASIDE THE ORDERS PASSED BY THE INCOME-TAX APPELLATE TRIBUNAL, BENGALURU IN IT(TP)A No.1447/BANG/2019 DATED 17/05/2022 FOR ASSESSMENT YEAR 2013-2014 ANNEXURE-D CONFIRMING THE ORDER OF THE APPELLATE COMMISSIONER AND CONFIRM THE ORDER PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BENGALURU.

THIS APPEAL, COMING ON FOR ADMISSION THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE S.G.PANDIT and HON'BLE MR. JUSTICE K. V. ARAVIND

ORAL JUDGMENT

(PER: HON'BLE MR. JUSTICE S.G.PANDIT)

Heard learned counsel Sri.M.Dilip, standing counsel for appellants and learned counsel Sri.Ankur P.D., for respondent. Perused the entire appeal papers.

2.

It is pointed out that the tax effect in the above appeal is Rs.50,37,051/-. Under Circular No.09/2024 dated 17.09.2024, the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes has enhanced the Monetary Limit to file appeals before the High Court to

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HC-KAR NC: 2025:KHC:35636-DB ITA No. 177 of 2023

Rs.2,00,00,000/-. The said circular would apply even to pending appeals also.

3.

In the light of the above, the appeal is dismissed as not maintainable. However, liberty is granted to the appellants to seek revival of the appeal, if any exceptions are made out.

Sd/- (S.G.PANDIT) JUDGE

Sd/- (K. V. ARAVIND) JUDGE

VBS List No.: 1 Sl No.: 19

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