SAP LABS INDIA PRIVATE LIMITED vs INCOME TAX OFFICER CIRCLE 6 (1) (1) BANGALORE — C.A. No. 8463/2022
Case under Section XII-B. Status: DISPOSED.
CNR: SCIN010383322018
Filing Date
10-10-2018 12:00 AM
Registration No
C.A. No. 008463 / 2022
Diary Number
38332/2018
Order Date
19-04-2023
Document Type
Judgement - of Main Case
Neutral Citation
2023 INSC 394
Disposal Type
Appeals Allowed
Acts & Sections
Petitioner(s)
SAP LABS INDIA PRIVATE LIMITED
Adv. AMBHOJ KUMAR SINHA[P-1]
Respondent(s)
INCOME TAX OFFICER CIRCLE 6 (1) (1) BANGALORE
Adv. RAJ BAHADUR YADAV[R-1]
Hearing History
Judge: HON'BLE MR. JUSTICE M.R. SHAH and HON'BLE MR. JUSTICE C.T. RAVIKUMAR
Fixed Date by Court
Fixed Date by Court
Fixed Date by Court
Fixed Date by Court
Fixed Date by Court
| Date | Purpose |
|---|---|
| 19-04-2023 | Fixed Date by Court |
| 15-11-2022 | Fixed Date by Court |
| 10-11-2022 | Fixed Date by Court |
| 03-11-2022 | Fixed Date by Court |
| 02-11-2022 | Fixed Date by Court |
Orders in this case
Summary The Supreme Court allowed a batch of Civil Appeals by the Revenue, holding that the Karnataka High Court erred in treating transfer pricing determinations by the Income Tax Tribunal as absolutely final and immune from scrutiny under Section 260A of the IT Act. The Court clarified that while the Tribunal is the primary fact-finding authority, High Courts can examine whether transfer pricing guidelines under Chapter X of the IT Act and Rules 10A-10E were properly followed, and whether findings are perverse; determinations made "de hors" statutory guidelines constitute substantial questions of law. The matters were remitted to High Courts for fresh consideration within nine months. This case analysis is maintained by casestatus.in based on publicly available court records.
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