Special leave petition dismissed as rental income from companies qualifies as profits under section 10AThe SC dismissed a special leave petition regarding profits derived under section 10A. The case involved an assessee claiming income from rental receipts from two companies. The Tribunal had allowed the assessee's claim that rental income qualified as profits under section 10A. The Karnataka HC upheld this decision. The SC declined to interfere with the HC's order, citing its earlier decision in a related matter involving one of the tenant companies. The petition was dismissed without further consideration, effectively confirming that rental income from the specified companies could be treated as eligible profits under the relevant tax provision.

The Supreme Court, in an order authored by Hon'ble Justices Surya Kant and Joymalya Bagchi, condoned delay due to the case's peculiar facts but declined to interfere with the impugned High Court of Karnataka order dated 22.11.2022. Relying on the precedent set in the Court's order dated 05.08.2024 in Diary No.25767/2024 (Pr. Commissioner Of Income Tax & Anr. vs. M/s Infosys Ltd.), the Court dismissed the Special Leave Petition and disposed of all pending applications.

Profits derived u/s 10A - Tribunal allowing claim of assessee that income derived from rental income from Infosys BPO Ltd. and BSNL Chennai Ltd - HELD THAT:- As in view of the order passed by this Court in M/s Infosys Ltd. [2024 (9) TMI 29 - SC ORDER] we see no ground to interfere with the impugned order passed by the High Court of Karnataka. Special Leave Petition is, accordingly, dismissed. THE PR COMMISSIONER OF INCOME TAX CIT (A) & ANR. Versus M/s INFOSYS LTD.
Income Tax
2025 (7) TMI 1319 - SC Order - TMI
SUPREME COURT - SC
Dated:- 18-7-2025
SPECIAL LEAVE PETITION (CIVIL) DIARY NO(S). 27172/2025 - -
Income Tax
51880278 HON'BLE MR. JUSTICE SURYA KANT And HON'BLE MR. JUSTICE JOYMALYA BAGCHI For the Petitioner : Mr. Raghavendra P Shankar, A.S.G. Mr. Raj Bahadur Yadav, AOR Mr. Karan Lahiri, Adv. Mr. Pratyush Srivastava, Adv. Mr. Udit Dedhiya, Adv ORDER UPON hearing the counsel the Court made the following. 1. In the peculiar facts and circumstances of this case, delay is condoned. 2. However, in view of the order dated 05.08.2024 passed by this Court in Diary No.25767/2024 (Pr. Commissioner Of Income Tax & Anr. vs. M/s Infosys Ltd.), we see no ground to interfere with the impugned order dated 22.11.2022 passed by the High Court of Karnataka. 3. The Special Leave Petition is, accordingly, dismissed. 4. All pending applications, if any, also stand disposed of.
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2025 (7) TMI 1319