Karnataka in Dell International Services India (P.) Ltd. v. Asstt. CIT

382 ITR 37High Court2016#16286 most cited
6

judgments rely on this decision, according to BharatTax’s citation analysis of 348,607 Indian tax judgments — from 2017 to 2025.

Also reported as

88 Taxmann.com 451

Issues it is cited on

disallowance under section 40(a)(ia)working capital adjustmentsection 194hbenchmarking analysisright to receivedirections of the drpcomparable companiesmercantile system of accountingarm's length pricesection 92casection 92csection 40(a)

Judgments citing Karnataka in Dell International Services India (P.) Ltd. v. Asstt. CIT

Bosch Automotive Electronics India Private Limited vs. Deputy Commissioner Income Tax

The appeal is allowed and the Tribunal's

ITA/104/2025HC Karnataka29 Oct 2025

Bench: B M SHYAM PRASAD,T.M.NADAF

Section 260

…- 1 - HC-KAR NC: 2025:KHC:43159-DB ITA No. 104 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 29TH DAY OF OCTOBER, 2025 PRESENT THE HON'BLE MR. JUSTICE B M SHYAM PRASAD AND THE HON'BLE MR. JUSTICE T.M.NADAF INCOME TAX APPEAL NO. 104 OF 2025 BETWEEN: BOSCH AUTOMOTIVE ELECTRONICS INDIA PRIVATE LIMITED INDIA PRIVATE LIMITED, C/O BOSCH LTD. BUILDING NO. 703, ELECTRONIC CITY, SO NAGANATHAPURA, BANGALORE, 560100 REPRESENTED HEREIN BY ITS COMPANY SECRETARY. …APPELLANT (BY SRI. T. SURYANARAYANA., SENIOR ADVOCATE FOR MS. TANMAYEE RAJKUMAR.…

Dell International Services India Private Limited, Bangalore vs. JCIT, Bangalore

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is partly allowed for statistical purposes

ITA 642/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Nov 2022AY 2011-12

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144CSection 92CSection 92C(3)

…l further remanded the matter to the Assessing Officer vide order dated 13-2-2015. The same was challenged by the assessee before the Hon'ble High Court of Karnataka in Dell International Services India (P.) Ltd. v. Asstt. CIT [2017] 88 taxmann.com 451/[2016] 382 ITR 37 (Kar.), set aside the remand order passed by the Tribunal and directed the Tribunal to decide the matter on merits. Pursuant to the judgment of the Hon'ble High Court of Karnataka dated 3-2-2016, the order dated 18-3-2016 was passed by this Tribunal in ITA Nos. 362 & 363/Bang/2007, dismissing the appeal filed by the Revenue (finding reproduced sup…

JCIT, Bangalore vs. M/S Dell International Services India Pvt. Ltd., Bangalore

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is partly allowed for statistical purposes

ITA 641/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Nov 2022AY 2011-12

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Sri.Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144CSection 92CSection 92C(3)

…l further remanded the matter to the Assessing Officer vide order dated 13-2-2015. The same was challenged by the assessee before the Hon'ble High Court of Karnataka in Dell International Services India (P.) Ltd. v. Asstt. CIT [2017] 88 taxmann.com 451/[2016] 382 ITR 37 (Kar.), set aside the remand order passed by the Tribunal and directed the Tribunal to decide the matter on merits. Pursuant to the judgment of the Hon'ble High Court of Karnataka dated 3-2-2016, the order dated 18-3-2016 was passed by this Tribunal in ITA Nos. 362 & 363/Bang/2007, dismissing the appeal filed by the Revenue (finding reproduced sup…

Dell India Private Ltd., Bangalore vs. JCIT, Bangalore

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is partly allowed for statistical purposes

ITA 562/BANG/2015[2010-11]Status: DisposedITAT Bangalore18 Aug 2022AY 2010-11

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, Senior AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92C

…l further remanded the matter to the Assessing Officer vide order dated 13-2-2015. The same was challenged by the assessee before the Hon'ble High Court of Karnataka in Dell International Services India (P.) Ltd. v. Asstt. CIT [2017] 88 taxmann.com 451/[2016] 382 ITR 37 (Kar.), set aside the remand order passed by the Tribunal and directed the Tribunal to decide the matter on merits. Pursuant to the judgment of the Hon'ble High Court of Karnataka dated 3-2-2016, the order dated 18-3-2016 was passed by this Tribunal in ITA Nos. 362 & 363/Bang/2007, dismissing the appeal filed by the Revenue (finding reproduced sup…

M/S Metahelix Life Sciences Limited vs. The Deputy Commissioner of Income Tax

The appeal is dismissed

ITA/75/2018HC Karnataka22 Nov 2018

Bench: The Hon'Ble Mr. Justice Ravi Malimath

Section 142(1)Section 143(2)Section 143(3)Section 260

…erefore, we do not find any ground in this appeal. 8. Further, the appellant’s counsel relies on the judgment in the case of DELL INTERNATIONAL SERVICES INDIA (P.) LTD. v. ASSISTANT COMMISSIONER OF INCOME TAX reported in [(2016) 382 ITR 37 (KARN)] with reference to paragraph No.8 and contends that the Tribunal ought to have arrived at a conclusion rather than remanding the matter further back to the Assessing Officer. We have considered the said judgment. However, the facts narrated therein would indicate that the matter was initially remanded by the High Court to the Trib…

Kamakshi Hospitality Pvt. Ltd., Jaipur vs. DCIT, Jaipur

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

ITA 481/JPR/2016[2010-11]Status: DisposedITAT Jaipur15 Dec 2017AY 2010-11
For Appellant: Shri Rajeev Sogani, CAFor Respondent: Shri R.A. Verma, Addl. CIT - DR &
Section 132Section 153ASection 69

…be upheld. The matter should not be set aside on general ground as it amounts to causing the assessee injustice and giving the AO another innings. Besides it is not explicit that AO insisted for confirmations.” Dell International Services India P. Ltd. [2016] 382 ITR 37 (KAR) “it was a settled law that remand was not a power to be exercised in a routine manner and should be used sparingly as an exception only when the facts warranted such course of action.” C. OTHER BENCHES Lalitha Karan v. ACIT, Hyderabad ITA No. 1130/ Hyd /2015 “7.6 Litigation in the Bombay, particularly, under the Maharashtra Rent Control Ac…

Karnataka in Dell International Services India (P.) Ltd. v. Asstt. CIT (382 ITR 37) — Cited in 6 Judgments | BharatTax