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HC-KAR NC: 2025:KHC:25862-DB ITA No. 248 of 2018
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.248 OF 2018 BETWEEN:
ABB FZ - LLC C/O ABB LTD, 21ST FLOOR, WORLD TRADE CENTRE, DR. RAJKUMAR ROAD, MALLESHWARAM (WEST) BANGALORE – 560 055 REPRESENTED HEREIN BY ITS AUTHORIZED SIGNATORY, MR. JAYANTA KUMAR CHATTERJEE
…APPELLANT (BY MS. MANASA ANANTHAN, ADVOCATE FOR MS. TANMAYEE RAJKUMAR, ADVOCATE)
AND:
THE DEPUTY COMMISSIONER IF INCOME -TAX (INTERNATIONAL TAXATION) (ERSTWHILE INCOME-TAX OFFICER, INTERNATIONAL TAXATION) CIRCLE, 1(1)) 4TH FLOOR, BMTC BUIDLING, KORAMANAGARA, BANGALORE – 560 095
Digitally signed by MADHUSHREE H Location: High Court of Karnataka
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HC-KAR NC: 2025:KHC:25862-DB ITA No. 248 of 2018
COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CR BUILDING, QUEENS ROAD, BANGALORE – 560 001 …RESPONDENTS (BY SRI. E.I.SANMATHI, ADVOCATE)
THIS ITA IS FILED UNDER SECTION 260-A OF INCOME TAX ACT 1961, PRAYING TO a) FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED ABOVE; b) ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 29.11.2017 PASSED BY THE TRIBUNAL IN IT(TP)A NO.2102/BANG/2016 (ANNEXURE- F); AND c) PASS SUCH OTHER OR SUITABLE ORDERS AS THIS HON'BLE COURT DEEMS FIT TO PASS ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE AND IN THE INTERESTS 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)
Memo dated 03.06.2025 is filed by the learned counsel for the appellant stating that the appellant has settled the dispute under the provisions of the Direct Tax Vivad Se Vishwas Scheme, 2024 and as such, seeks permission to withdraw the appeal.
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HC-KAR NC: 2025:KHC:25862-DB ITA No. 248 of 2018
Memo is placed on record.
Learned counsel for the appellant further seeks liberty to revive the appeal in case the Scheme does not proceed in a beneficial manner or attains finality. 4. The appeal is dismissed as withdrawn, with liberty as sought.
Sd/- (S.G.PANDIT) JUDGE
Sd/- (T.M.NADAF) JUDGE
MH/- List No.: 1 Sl No.: 3