PR COMMISSIONER OF INCOME TAX-4 vs. M/S BROADCOM COMMUNICATIONS

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ITA/248/2020HC KarnatakaKAHC01054234201927 June 2025Bench: S.G.PANDIT,T.M.NADAF2 pages
AI SummaryDismissed

What did the High Court hold?

The High Court noted the settlement under the Vivad se Vishwas Scheme and acknowledged that the appeal no longer survived for consideration. Consequently, the appeal was disposed of.

What were the facts?

The appeal was filed by the Revenue against an order of the ITAT. The dispute between the Revenue and the assessee was settled under 'The Direct Tax Vivad se Vishwas Scheme, 2024'.

What were the issues?

The primary issue was whether the appeal filed by the Revenue was still maintainable after the settlement of the dispute under the 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

- 1 -

HC-KAR NC: 2025:KHC:22624-DB ITA No. 248 of 2020

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 27TH DAY OF JUNE, 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 2020 BETWEEN: 1. PR. COMMISSIONER OF INCOME TAX-4 BMTC COMPLEX, KORAMANGALA BENGALURU.

2.

THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 1(1) (2) BENGALURU. …APPELLANTS (BY SRI. SANMATHI E. I., ADV.)

AND: M/S. BROADCOM COMMUNICATIONS TECHNOLOGIES PRIVATE LIMITED (EARLIER KNOWN AS BROADCOM INDIA RESEARCH PRIVATE LIMITED) S1, WIPRO ELECTRONIC CITY SPECIAL ECONOMIC ZONE, DODDATHOGUR VILLAGE BEGUR HOBLI, ELECTRONIC CITY BANGALORE – 560100.

…RESPONDENT

(BY SMT. MANASA ANANTHAN, ADV. FOR SMT. TANMAYEE RAJKUMAR, ADV.)

THIS APPEAL IS FILED UNDER SECTION 260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 14.06.2019 PASSED IN IT (TP)A NO.1929/BANG/2017, FOR THE ASSESSMENT YEAR 2013-2014.

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

Digitally signed by MARIGANGAIAH PREMAKUMARI Location: HIGH COURT OF KARNATAKA

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HC-KAR NC: 2025:KHC:22624-DB ITA No. 248 of 2020

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

Learned counsel Sri.E.I.Sanmathi for appellants/Revenue on instructions submit that dispute between the appellants and respondent is settled under ‘The Direct Tax Vivad se Vishwas Scheme, 2024 and Form-4 has been issued. Further, learned counsel would submit that in view of the above development, appeal would no more survive for consideration.

2.

Submission of the learned counsel is placed on record.

3.

Appeal is disposed of as having become infructous. Sd/- (S.G.PANDIT) JUDGE

Sd/- (T.M.NADAF) JUDGE

NC CT:bms: List No.: 1 Sl No.: 2

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