Devas Multimedia Pvt. Ltd. v. PCIT

419 ITR 391High Court2019#17890 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 348,252 Indian tax judgments — from 2022 to 2026.

Sections most often in play

Section 263Section 139(1)Section 143(3)Section 144CSection 234CSection 253(d)Section 36(1)(va)
Read the full judgment

Issues it is cited on

section 144c(13)final assessment orderdraft assessment ordersection 263section 26opportunity of being heardindiabusinesscompanyinterestsection 143(3)total income

Judgments citing Devas Multimedia Pvt. Ltd. v. PCIT

Mondelez India Foods Private Limited, Mumbai vs. Principal Commissioner of Income Tax -8, Mumbai

In the result, the appeal by the assessee stands partly allowed

ITA 3689/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Mar 2026AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Prabhash Shankarmondelez India Foods Vs. Principal Commissioner Private Limited Of Income-Tax, Mumbai- Unit No. 2001, 20Th Floor, 8 Tower-3 (Wing C), One 611, 6Th Floor, Aayakar International Cente Bhavan, Maharshi (Formerly Indiabulls Finance Karve Road, Mumbai- Centre) Parel, Mumbai- 400020 400013 Pan/Gir No. Aaacc0460H (Applicant) (Respondent) Assessee By Shri Nishant Thakker & Hiten Thakkar Revenue By Shri Krishna Kumar (Sr. Dr.) Date Of Hearing 19.02.2026 Date Of Pronouncement 27.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 20.03.2025 Passed U/S 263 Of The Income Tax Act, 1961 (‘The Act’), By The Principal Commissioner Of Income Tax – Pcit, Mumbai-8 (‘The Ld. Pcit’) For The Assessment Year 2018-19. The Following Grounds Are Reproduced Below:

Section 143(3)Section 144CSection 144C(13)Section 263

…gh Court exposition noted above and the other decisions of Hon'ble Jurisdictiefial High court referred above. 13 Mondelez India Foods Private Limited 25 The case of Devas Multimedia (P.) Ltd. v. Pr. CIT [2019] 111 taxmann.com 494/[2020] 268 Taxman 150/[2019] 419 ITR 391 by the Hon'ble Karnataka High Court was in connection with the writ petition filed by the assessee, where assessee has objected to the notice issued u/s. 263 of the Act. Furthermore, Hon'ble High Court has expounded that writ court cannot examine the validity of notice on merits. Furthermore, the said decision has distinguished following decision…

Comer Industries India Private Limited, Bangalore vs. DCIT, Circle 2(2)(1), Bangalore

In the result, the appeal by the assessee is dismissed

ITA 1228/BANG/2025[2017-18]Status: DisposedITAT Bangalore27 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Balasubramanyam, CAFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru
Section 139(1)Section 234CSection 263Section 36(1)(va)

…mmissioner of Income Tax, Circle- 12(1)(2), Mumbai [2020] 116 taxmann.com 933 (Mumbai - Trib.). 18. Devas Multimedia (P.) Ltd. vs. Principal Commissioner of Income-tax, Bangalore [2019] 111 taxmann.com 494 (Karnataka)/[2020] 268 Taxman 150 (Karnataka)/[2019] 419 ITR 391 (Karnataka)[27-09-2019] has held that "18. It is undisputed that Draft Assessment Order was notified by the AO in view of the fact that assessee's business involved International Money Transaction. Petitioner/assessee was entitled to have an opportunity to look into Draft Assessment Order. He had option either to accept or to submit objections on…

Tata Steel Limited, Mumbai vs. The Principle Commissioner of Income Tax, Mumbai

In the result, both the appeals of the assessee are allowed

ITA 1316/MUM/2022[2012-2013]Status: DisposedITAT Mumbai23 Dec 2022AY 2012-2013
Section 115JSection 143(3)Section 263Section 36(1)(iii)

…the case of Philips India Ltd. vs. PCIT in ITA No.1142/Kol/2016 dated 27/03/2019 wherein the similar proposition was addressed. 3.2. In this regard, we find that the Hon‟ble Karnataka High Court in the case of Devas Multimedia Pvt. Ltd. vs. PCIT reported in 419 ITR 391 (Kar) M/s. Tata Steel Limited had also addressed the very same issue. The relevant operative portion of the said order is reproduced hereunder:- 18. It is undisputed that Draft Assessment Order was notified by the AO in view of the fact that assessee's business involved International Money Transaction. Petitioner/assessee was entitled to have a…

Tata Steel Limited, Mumbai vs. The Principle Commissioner of Income Tax, Mumbai-2, Mumbai

In the result, both the appeals of the assessee are allowed

ITA 1315/MUM/2022[2011-2012]Status: DisposedITAT Mumbai23 Dec 2022AY 2011-2012
Section 115JSection 143(3)Section 263Section 36(1)(iii)

…the case of Philips India Ltd. vs. PCIT in ITA No.1142/Kol/2016 dated 27/03/2019 wherein the similar proposition was addressed. 3.2. In this regard, we find that the Hon‟ble Karnataka High Court in the case of Devas Multimedia Pvt. Ltd. vs. PCIT reported in 419 ITR 391 (Kar) M/s. Tata Steel Limited had also addressed the very same issue. The relevant operative portion of the said order is reproduced hereunder:- 18. It is undisputed that Draft Assessment Order was notified by the AO in view of the fact that assessee's business involved International Money Transaction. Petitioner/assessee was entitled to have a…

Brocade Communications Systems Private Limited, Bengluru vs. Principal Commissioner of Income Tax-1, Bengaluru

In the result, the appeal filed by the assessee stands partly allowed

ITA 656/BANG/2021[2013-14]Status: DisposedITAT Bangalore30 Aug 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14 M/S. Brocade Communications Systems Pvt. Ltd., Floor 3, B & C Wing & The Principal Floor 8, D Wing, S1 Commissioner Of Wipro Electronic City Income Tax – 1, Sez, Doddathogur Bengaluru. Vs. Village, Bengaluru – 560 100. Pan: Aaccb4490N Appellant Respondent : Smt. Tanmayee Rajkumar, Assessee By Advocate : Smt. Priyadarshini Revenue By Baseganni, Addl. Cit (Dr) Date Of Hearing : 28-07-2022 Date Of Pronouncement : 30-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By The Assessee Against Order Dated 18/03/2020 Passed By The Ld.Pr.Cit For A.Y. 2013-14 On Following Grounds Of Appeal: “1. The Order Of The Principal Commissioner Of Income Tax ('Pr.Cit') Passed Under Section 263 Of The Income-Tax Act, 1961 ('The Act'), Is Bad In Law & Liable To Be Quashed. 2. The Learned Pr.Cit Erred In Law & Facts In Concluding That The Order Of The Assessing Officer ('Ao') Is "Erroneous

For Respondent: Smt. Tanmayee Rajkumar
Section 10ASection 143(3)Section 144C(5)Section 263Section 28Section 92C

…. PCIT in ITA No. 709/Bang/2021 by order dated 27/06/2022 for A.Y. 2013-14 wherein a similar argument was dismissed by this Tribunal placing reliance on the decision of Hon’ble Karnataka High Court in case of Devas Multimedia Pvt. Ltd. vs. Prl.CIT reported in 419 ITR 391. He submitted that the decision relied by the Ld.AR rendered by Hon’ble Mumbai Tribunal has been also dealt with in the said decision. We have perused the submissions advanced by both sides in the light of records placed before us. 4. We note that Coordinate Bench of this Tribunal in case of Adamas Builders Pvt. Ltd. vs. PCIT (supra) has observed…

Devas Multimedia Pvt. Ltd. v. PCIT (419 ITR 391) — Cited in 5 Judgments | BharatTax