Deputy Commissioner of Income Tax (International Taxation), Circle 1(1) v. AD2PRO Media Solutions Inc., USA

1. FACTS OF THE CASE

Revenue brought WA 328/2024 under section 4 of the Karnataka High Court Act against the Single Judge’s 13 April 2023 order in WP 4233/2021. That order had granted relief to assessees in a batch of petitions.

Source: PDF p. 2

2. DISCUSSION BY THE COURT

On examining the paper book, the Division Bench found no error in applying the ratio of ITA 232/2020 and connected matters to the subject petition.

Source: PDF p. 2

3. JUDICIAL DECISION

The writ appeal was rejected as without merit; the order states that costs were made easy.

Source: PDF p. 3

4. OUTCOME

The respondent retained the relief granted by the Single Judge. This three-page appellate order does not set out the underlying tax computation or detailed relief.

Source: PDF p. 3

5. Expert Comments

AKHB editorial analysis, distinct from the Court’s findings.

Identify precisely what was affirmed

The appellate conclusion approves application of the identified coordinate-Bench ratio. The supplied order does not reproduce the Single Judge’s detailed directions, so a particular refund amount or tax exemption cannot be reconstructed from it.

Source: PDF p. 2

Do not import the section 260 A route into a writ appeal

This proceeding is expressly under section 4 of the Karnataka High Court Act. The earlier ITA docket is precedent, not the procedural route of WA 328/2024.

Source: PDF p. 1

Keep the source limitation visible

No assessment year, charging section or treaty article appears in this short order. The note therefore reports the appellate result without inventing the missing substantive background.

Source: PDF p. 3