Writ petitions challenging Section 154 orders recomputing outstanding dues from Associated Enterprises for AYs 2017-18 and 2018-19. Dispute settled via Mutual Agreement Procedure under India-USA DTAA; petitions withdrawn as infructuous.
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HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 12TH DAY OF MARCH, 2026
BEFORE
THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV
WRIT PETITION NO. 27816 OF 2024 (T-IT)
C/W
WRIT PETITION NO. 27815 OF 2024 (T-IT)
IN WP No. 27816/2024
BETWEEN:
Digitally signed by VIJAYA P Location: HIGH COURT OF KARNATAKA
…PETITIONER
(BY SMT. TANMAYEE RAJKUMAR, ADVOCATE)
AND:
HC-KAR
80 FEET ROAD, KORAMANGALA, BANGALORE - 560 095.
…RESPONDENTS
(BY SRI. E.I. SANMATHI, ADVOCATE)
THIS W.P. IS FILED UNDER ARTICLES 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ORDER DATED 19.09.2024 (ANNEXURE-G) BEARING DIN ITBA/COM/F/17/2024-25/1068846231(1) PASSED BY THE 1ST RESPONDENT FOR THE ASSESSMENT YEAR 2017-18 AND ETC.
IN WP NO. 27815/2024
BETWEEN:
...PETITIONER
(BY SMT. TANMAYEE RAJKUMAR, ADVOCATE)
AND:
NC: 2026:KHC:14907 WP No. 27816 of 2024 C/W WP No. 27815 of 2024
HC-KAR
...RESPONDENTS
(BY SRI. E.I. SANMATHI, ADVOCATE)
THIS W.P. IS FILED UNDER ARTICLES 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ORDER DATED 19.09.2024 (ANNEXURE-'F') BEARING DIN ITBA/COM/F/17/2024-25/1068847866(1) PASSED BY THE 1ST RESPONDENT FOR THE ASSESSMENT YEAR 2018-19 AND ETC.
THESE PETITIONS COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S SUNIL DUTT YADAV
ORAL ORDER
Learned counsel for the petitioner has filed a memo
for withdrawal, which reads as under:
"MEMO FOR WITHDRAWAL
The Advocate for the Petitioner most humbly submits as under:
The above petition is filed questioning the legality and validity of the order dated 19.09.2024 passed by the 1st Respondent under Section 154 of
HC-KAR
the Income-tax Act, 1961, recomputing the outstanding dues receivable from the Petitioner's Associated Enterprises ("AEs") for the assessment year 2017-18. During the pendency of the above petition, the Petitioner has settled the dispute involved in the present petition by invoking the provisions of Mutual Agreement Procedure ("MAP") under the Double Taxation Avoidance Agreement between India and United States of America. Pursuant to the above, an order dated 27.01.2026 was passed in terms of Rule 44G of the Income-tax Rules, 1962. In view of the above, the present petition has become infructuous and thus the Petitioner craves leave of the Hon'ble Court to withdraw the above petition.
Wherefore, it is most humbly prayed that this Court be pleased to dispose of the above petition as "withdrawn" in the interests of justice and equity."
2. Taking note of the contents of the memo, the
petition is disposed of as not calling for adjudication.
Sd/(S SUNIL DUTT YADAV) JUDGE
SHS
2 provisions across 2 enactments
CA (India) Technologies Pvt Ltd.
Deputy Commissioner of Income-Tax, Transfer Pricing, DC/ACIT TP 1(1)(2)
Deputy Commissioner of Income-Tax, Circle 2(2)(1)
S Sunil Dutt Yadav
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
