Case Note & Summary
This judgment extract from the High Court of Karnataka at Bengaluru contains the cause title and appeal particulars for a batch of twelve income tax appeals and one cross objection consolidated for hearing. The proceedings arise under Section 260-A of the Income-tax Act, 1961, which provides for appeals to the High Court from orders of the Income Tax Appellate Tribunal. The batch includes ITA No.10/2011, ITA No.23/2011, ITA No.24/2011, ITA No.44/2015, ITA No.128/2015, ITA No.469/2015, ITA No.492/2016, ITA No.514/2016, ITA No.884/2017, ITA No.955/2017, ITA No.956/2017, and I.T Appeal Cross Objection No.1 of 2018. The first appeal, ITA No.10/2011, is filed by SAP Labs India Private Limited against the Income Tax Officer, Ward-12(2), Bangalore, arising from ITA No.398/Bang/2008 dated 30-08-2010 for assessment year 2003-2004. The other appeals are filed by various revenue authorities such as the Commissioner of Income Tax, Assistant Commissioner of Income Tax, Deputy Commissioner of Income Tax, Principal Commissioner of Income Tax, and Additional Commissioner of Income Tax against several assessee companies including M/s SAP India Pvt Ltd, M/s BearingPoint Property Services Private Limited (formerly BearingPoint Business Consulting Private Ltd), M/s Msource (India) Pvt. Ltd., M/s Subex Ltd, M/s Nett App India Pvt. Ltd., M/s Swiss Re Global Business Solutions India Private Limited (formerly Swiss Re Shared Services (India) Private Limited), and M/s Tavant Technologies India Pvt Ltd. The appeals challenge orders of the Income Tax Appellate Tribunal, Bengaluru, passed on various dates for assessment years ranging from 2003-04 to 2012-13. The extract records that the appeals were reserved on 02-04-2026 and pronounced on 28-08-2026. It lists the advocates for the parties, including Sri D.D. Nageshwar Rao for the assessee in some appeals, the Additional Solicitor General and standing counsel for the Revenue, and senior counsel for several private respondent companies. However, the extract does not include the substantial questions of law framed by the Court, the arguments advanced by the parties, the Court's analysis of statutory provisions or precedents, or the operative directions or final decision. Therefore, the substantive legal conclusions, ratio decidendi, and final outcome of the batch cannot be ascertained from the provided text. The document is limited to the procedural and party details of the consolidated appeals before the High Court.
Issue of Consideration
Case Details
2026 LawText (KAR) (08) 88
ITA No.10 of 2011 C/W ITA No.23 of 2011, ITA No.24 of 2011, ITA No.44 of 2015, ITA No.128 of 2015, ITA No.469 of 2015, ITA No.492 of 2016, ITA No.514 of 2016, ITA No.884 of 2017, ITA No.955 of 2017, ITA No.956 of 2017 and I.T Appeal Cross Objection No.1 of 2018
S.G. Pandit, K. V. Aravind
D.D. Nageshwar Rao, N. Venkataraman, E. I. Sanmathi, Sushal Tiwari, M. Dilip, K.K. Chythanya, S. Sharath, T. Suryanarayana, Tanmayee Rajkumar, K. Mallahar Rao
SAP Labs India Private Limited (ITA No.10/2011); Commissioner of Income Tax and other revenue authorities (all other connected appeals)
Income Tax Officer, Ward-12(2), Bangalore (ITA No.10/2011); various assessee companies including M/s SAP India Pvt Ltd, M/s BearingPoint Property Services Private Limited, M/s Msource (India) Pvt. Ltd., M/s Subex Ltd, M/s Nett App India Pvt. Ltd., M/s Swiss Re Global Business Solutions India Private Limited, M/s Tavant Technologies India Pvt Ltd (all other connected appeals)
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Nature of Litigation
Batch of income tax appeals and a cross objection filed under Section 260-A of the Income Tax Act, 1961 before the High Court of Karnataka against orders of the Income Tax Appellate Tribunal, Bengaluru for various assessment years.
Remedy Sought
Various appellants sought formulation of substantial questions of law, setting aside of the appellate orders passed by the Income Tax Appellate Tribunal, and other appropriate reliefs in the interest of justice.
Filing Reason
The appeals arose out of orders passed by the Income Tax Appellate Tribunal, Bengaluru, for different assessment years; both revenue authorities and assessee companies challenged those orders on questions of law.
Previous Decisions
Orders passed by the Income Tax Appellate Tribunal, Bengaluru, in multiple appeals, including ITA No.398/Bang/2008 dated 30-08-2010 for assessment year 2003-04, ITA No.418/Bang/2008 dated 30-08-2010 for assessment year 2003-04, ITA No.1380/Bang/2012 dated 21-08-2014 for assessment year 2008-09, M.P.No.40/Bang/2014 dated 28-11-2014, ITA No.1482/Bang/2010 dated 17-04-2015 for assessment year 2006-07, ITA No.223/Bang/2014 dated 16-03-2016 for assessment year 2009-10, IT(TP)A No.1614/Bang/2014 dated 11-05-2016 for assessment year 2009-10, ITA No.2315/Bang/2016 dated 13-04-2017 for assessment year 2012-13, IT(TP)A No.292/Bang/2014 dated 31-05-2017 for assessment year 2007-08, and IT(TP)A No.1592/Bang/2012 dated 31-05-2017 for assessment year 2008-09.
Judgment Excerpts
THIS ITA IS FILED U/S.260-A OF I.T.ACT, 1961 ARISING OUT OF ORDER DATED 30-08-2010 PASSED IN ITA No.398/BANG/2008, FOR THE ASSESSMENT YEAR 2003-2004, PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN, ALLOW THE APPEAL AND SET ASIDE THE ORDER PASSED BY THE ITAT BANGALORE IN ITA No.398/BANG/2008, DATED 30-08-2010.
RESERVED ON : 02.04.2026 PRONOUNCED ON: 28.08.2026
Procedural History
Multiple income tax appeals and one cross objection were filed before the High Court of Karnataka under Section 260-A of the Income Tax Act, 1961, challenging orders of the Income Tax Appellate Tribunal, Bengaluru, for various assessment years. The appeals were reserved on 02-04-2026 and pronounced on 28-08-2026. The individual appeals arose from ITAT orders such as ITA No.398/Bang/2008 dated 30-08-2010, ITA No.418/Bang/2008 dated 30-08-2010, ITA No.1380/Bang/2012 dated 21-08-2014, M.P.No.40/Bang/2014 dated 28-11-2014, ITA No.1482/Bang/2010 dated 17-04-2015, ITA No.223/Bang/2014 dated 16-03-2016, IT(TP)A No.1614/Bang/2014 dated 11-05-2016, ITA No.2315/Bang/2016 dated 13-04-2017, IT(TP)A No.292/Bang/2014 dated 31-05-2017, and IT(TP)A No.1592/Bang/2012 dated 31-05-2017, as indicated in the appeal memoranda.
Acts & Sections
- Income Tax Act, 1961: 260-A
