PRINCIPAL COMMISSIONER OF INCOME TAX-4 vs. M/S LSI INDIA RESEARCH & DEVELOPMENT PVT LTD

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ITA/43/2019HC KarnatakaKAHC01032517201902 April 2025Bench: KRISHNA S DIXIT,RAMACHANDRA D. HUDDAR2 pages
AI SummaryDismissed

What did the High Court hold?

The High Court acknowledged that the dispute had been settled under the 'Vivad Se Vishwas' Scheme. Consequently, the appeal was disposed of based on this settlement.

What were the facts?

The Income Tax Appellate Tribunal (ITAT) had passed an order concerning the assessment year 2009-2010. The revenue department filed an appeal against this order before the High Court. During the pendency of the appeal, the assessee settled the dispute under the 'Vivad Se Vishwas' Scheme.

What were the issues?

The primary issue was whether the appeal filed by the revenue department should be proceeded with when the underlying dispute was settled under a tax dispute resolution 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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NC: 2025:KHC:13738-DB ITA No. 43 of 2019

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 2ND DAY OF APRIL, 2025 PRESENT THE HON'BLE MR JUSTICE KRISHNA S DIXIT AND THE HON'BLE MR JUSTICE RAMACHANDRA D. HUDDAR INCOME TAX APPEAL NO. 43 OF 2019 BETWEEN:

1.

PRINCIPAL COMMISSIONER OF INCOME TAX-4 BMTC COMPLEX, KORAMANGALA BENGALURU.

2.

THE INCOME TAX OFFICER WARD -11(2), BENGALURU …APPELLANTS (BY SRI. SANMATHI E.I., ADVOCATE) AND:

M/S LSI INDIA RESEARCH & DEVELOPMENT PVT LTD (ERSTWHILE LSI RESEARCH (INDIA) PVT LTD.,) M/S LSI INDIA RESEARCH & DEVELOPMENT P. LTD., (ERSTWHILE LSI TECHNOLOGIES INDIA PVT LTD.,) BLOCK C, GLOBAL TECHNOLOGY PARK, MARATHAHALLI, OUTER RING ROAD DEVARABEESANAHALLI BENGALURU - 560 103. …RESPONDENT (BY SRI. MANASA ANANTHAN, ADVOCATE)

THIS INCOME TAX APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 07.09.2018 PASSED IN IT(TP)A NO. 44/BANG/2014 FOR THE ASSESSMENT YEAR 2009-2010, PRAYING THIS HONBLE COURT TO A. DECIDE THE FOREGOING QUESTION OF LAW AND/OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY

Digitally signed by SHAKAMBARI Location: High Court of Karnataka

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NC: 2025:KHC:13738-DB ITA No. 43 of 2019

THE HONBLE COURT AS DEEMED FIT. B. SET ASIDE THE APPELLATE ORDER DATED 07.09.2018 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, 'B' BENCH, BANGALORE, IN APPEAL PROCEEDINGS NO. IT(TP)A NO. 44/BANG/2014 FOR THE ASSESSMENT YEAR 2009-2010 AS SOUGHT FOR IN THIS APPEAL AND TO GRANT SUCH OTHER RELIEF AS DEEMED FIT, IN THE INTEREST OF JUSTICE.

THIS APPEAL, COMING ON FOR ORDERS, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: CORAM: HON'BLE MR JUSTICE KRISHNA S DIXIT and HON'BLE MR JUSTICE RAMACHANDRA D. HUDDAR

ORAL JUDGMENT (PER: HON'BLE MR JUSTICE KRISHNA S DIXIT) It is submitted by the learned counsel appearing for the assessee and not much disputed by the panel counsel appearing for the revenue that lis in this appeal has been settled under "Vivad Se Vishwas" Scheme and therefore, the same be accordingly disposed off.

Ordered accordingly and appeal is disposed off.

Sd/- (KRISHNA S DIXIT) JUDGE

Sd/- (RAMACHANDRA D. HUDDAR) JUDGE

DH, List No.: 1 Sl No.: 2

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