Income Tax Appellate Tribunal dismissed the appeal as questions of law did not arise in the impugned order; liberty reserved to raise questions in a subsequent appeal.
This page shows the compact analysis of this judgement. The full analysis — procedural history, issue-by-issue holdings with ratio and obiter, advocates, and paragraph-level evidence for every claim — is being added to the record in batches and will appear here when this judgement has been through it.
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IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 8TH DAY OF JULY, 2021
PRESENT
THE HON’BLE MR. JUSTICE SATISH CHANDRA SHARMA
AND
THE HON’BLE MR. JUSTICE NATARAJ RANGASWAMY
I.T.A. NO.96/2020
BETWEEN:
.... APPELLANTS
(BY SRI. SANMATHI .E.I, ADVOCATE)
AND:
M/S. MICROCHIP TECHNOLOGIES (INDIA) PVT LTD. NO.149-B, EPIP I PHASE INDUSTRIAL AREA, WHITEFIELD BENGALURU-560 066 PAN NO. AABCM 9868J
(BY SRI. SURYANARAYANA .T, ADVOCATE)
... RESPONDENT
THIS I.T.A. IS FILED UNDER SECTION 260-A OF INCOME TAX ACT 1961, PRAYING TO SET ASIDE THE APPELLATE ORDER DATED: 28.09.2019 PASSED BY THE
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INCOME TAX APPELLATE TRIBUNAL, ‘B’ BENCH, BANGALORE, IN APPEAL PROCEEDINGS IN I.T.(TP)A.NO.187(BANG)2014 (ANNEXURE-‘A’) FOR THE ASSESSMENT YEAR 2009-10 AS SOUGHT FOR IN THIS APPEAL; AND TO GRANT SUCH OTHER RELIEF AS DEEMED FIT.
THIS I.T.A. COMING ON FOR ORDERS THIS DAY, NATARAJ RANGASWAMY J. , DELIVERED THE FOLLOWING:
JUDGMENT
Learned counsel for the appellants submits that the questions of law which are proposed do not arise for consideration from out of the order, which is impugned in this appeal. Learned counsel seeks liberty to urge these questions of law in ITA No.212/2021. In that view of the matter, this appeal is disposed of holding that the proposed questions of law do not arise for consideration in this appeal. However, liberty is reserved to the revenue to urge these questions of law in the subsequent appeal filed in ITA No.212/2021.
Sd/JUDGE
Sd/JUDGE
KGR*
THE PRINCIPAL COMMISSIONER OF INCOME-TAX
THE DEPUTY COMMISSIONER OF INCOME-TAX
M/S. MICROCHIP TECHNOLOGIES (INDIA) PVT LTD.
SATISH CHANDRA SHARMA
NATARAJ RANGASWAMY
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
