THE PR. COMMISSIONER OF INCOME TAX vs. AUTOLIV INDIA PVT LTD

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ITA/417/2023HC KarnatakaKAHC01028998202309 July 2025Bench: S.G.PANDIT,T.M.NADAF3 pages
AI SummaryDismissed

What did the High Court hold?

The High Court disposed of the appeal as settled under the Vivad Se Vishwas Scheme. The Revenue was granted liberty to revive the appeal if the respondent failed to fulfill the scheme's conditions.

What were the facts?

The appeal was filed by the Revenue against an order of the Income Tax Appellate Tribunal. The respondent company had settled the issue under the Direct Tax Vivad Se Vishwas Scheme, 2024.

What were the issues?

The primary issue was the disposal of the appeal due to the settlement of the dispute under the Direct Tax Vivad Se Vishwas Scheme.

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:25050-DB ITA No. 417 of 2023

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 9TH 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.417 OF 2023 BETWEEN:

1.

THE PR. COMMISSIONER OF INCOME TAX 5TH FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU – 560 095

2.

THE INCOME TAX OFFICER WARD-1(1)(2) PRESENT ADDRESS, DCIT CIRCLE-1(1)(1), 2ND FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU – 560 095 …APPELLANTS

(BY SRI. Y.V.RAVIRAJ & SRI. DILIP M, ADVOCATES)

AND:

AUTOLIV INDIA PVT. LTD., PLOT #31,32-P, 33-P, HI-TECH DEFENCE AND AEROSPACE PARK, IT SECTOR, JALA INDUSTRIAL AREA, HOBLI BENGALURU NORTH, YELAHANKA, BENGALURU – 562 149 PAN: AADCA 6222E

…RESPONDENT

Digitally signed by MADHUSHREE H Location: High Court of Karnataka

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HC-KAR NC: 2025:KHC:25050-DB ITA No. 417 of 2023

(BY MS. MANASA ANANTHAN, ADVOCATE FOR MS. TANMAYEE RAJKUMAR, ADVOCATE)

THIS ITA IS FILED UNDER SECTION 260-A OF THE INCOME TAX ACT, 1961, 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.3337/BANG/2018 DATED 21.11.2022 FOR ASSESSMENT YEAR 2014-2015 ANNEXURE-D AND CONFIRM THE ORDER OF THE DRP CONFIRMING THE ORDER PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU; iii) TO PASS SUCH OTHER SUITABLE ORDERS AS THIS HON’BLE COURT DEEMS FIT TO GRANT IN THE FACTS AND CIRCUMSTANCES OF THE CASE IN THE INTEREST OF JUSTICE AND EQUITY.

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

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)

Learned counsel for the respondent has filed memo for disposal, stating that the respondent has settled the issue involved in the above appeal under Direct Tax Vivad Se Vishwas Scheme, 2024. Hence, he submitted that the appeal needs to be disposed of.

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HC-KAR NC: 2025:KHC:25050-DB ITA No. 417 of 2023

2.

Sri.Y.V.Raviraj, learned counsel for the appellants pray for reserving liberty to revive the appeal in case there is failure on the part of the respondent to fulfill the conditions of the benefit granted under the Scheme. 3. Submissions of the learned counsel are placed on record. 4. In view of the settlement of the dispute/issue under the Scheme, the appeals stand disposed of with liberty as sought by appellants.

Sd/- (S.G.PANDIT) JUDGE

Sd/- (T.M.NADAF) JUDGE MH/- List No.: 1 Sl No.: 9

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