THE PR COMMISSIONER OF INCOME TAX vs. M/S BROADCOM INDIA RESEARCH PVT LTD

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ITA/331/2017HC KarnatakaKAHC01050015201727 June 2025Bench: S.G.PANDIT,T.M.NADAF2 pages
AI SummaryDismissed

What did the High Court hold?

The High Court noted that the dispute has been settled under the Vivad se Vishwas Scheme. Consequently, the appeal no longer survives for consideration.

What were the facts?

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

What were the issues?

Whether the appeal survives for consideration when the dispute has been settled 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:22625-DB ITA No. 331 of 2017

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. 331 OF 2017 BETWEEN: 1. THE PR. COMMISSIONER OF INCOME TAX 5TH FLOOR, BMTC BUILDING 80 FEET ROAD, KORAMANGALA BENGALURU-560095.

2.

THE ASST. COMMISSIONER OF INCOME TAX CIRCLE – 2(1)(1) 2ND BLOOR, BMTC BUILDING 80 FEET ROAD, KORMANGALA BENGALURU-560095. …APPELLANTS (BY SRI. SANMATHI E. I., ADV.)

AND: M/S. BROADCOM INDIA RESEARCH PVT. LTD., (NOW MERGED WITH BROADCOM COMMUNICATION TECHNOLOGIES PVT. LTD.,) CAMPUS 3A, 4TH FLOOR, RMZ ECOSPACE BELLANDUR VILLAGE, VARTHUR HOBLI BANGALORE – 560037. …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 13.07.2016 PASSED IN IT (TP)A NO.348/BANG/2015, FOR THE ASSESSMENT YEAR 2010-2011, ANNEX-D.

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:22625-DB ITA No. 331 of 2017

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.: 1

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