Himatsingka Seide Updates on Transfer Pricing Litigation Before Income Tax Appellate Tribunal
Himatsingka Seide Limited disclosed an update on its transfer pricing litigation before the Income Tax Appellate Tribunal, Kolkata, for Assessment Year 2008-09, involving corporate guarantee, inter-corporate loan, and export-related adjustments. The Tribunal dismissed the appeal and deleted additions of Rs. 6.90 crores, after which the Revenue's application for condonation of delay was accepted by the High Court, leading the company to propose filing an appeal before the Supreme Court. The litigation does not involve any key management personnel or promoters, and no settlement has been reached.

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Himatsingka Seide Limited has filed a disclosure with the stock exchanges on May 07, 2026, providing an update on its ongoing litigation with the Assistant Commissioner of Income Tax. The disclosure was made pursuant to Regulation 30 read with Part B of Schedule III of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, and in compliance with SEBI Master Circular No. HO/49/14/14(7)2025-CFD-POD2/I/3762/2026 dated January 30, 2026.
Nature of the Dispute
The litigation involves transfer pricing adjustments related to three distinct matters pertaining to Assessment Year 2008-09. The case is being heard before the Income Tax Appellate Tribunal, Kolkata, with the opposing party being the Assistant Commissioner of Income Tax. The key details of the dispute are outlined below:
| Parameter: | Details |
|---|---|
| Opposing Party: | Assistant Commissioner of Income Tax |
| Forum: | Income Tax Appellate Tribunal, Kolkata |
| Assessment Year: | 2008-09 |
The transfer pricing adjustments under dispute relate to the following:
- Corporate Guarantee provided by the company to its subsidiaries
- Inter-corporate loan provided by the company to its Associated Enterprise (AE)
- Exports made by the company to its subsidiary
Key Developments in the Proceedings
For Assessment Year 2008-09, both the Revenue and the company had filed appeals before the Income Tax Appellate Tribunal against the order passed by the Commissioner of Income Tax (Appeals). The Tribunal dismissed the appeal and deleted additions to the extent of Rs. 6.90 crores.
Subsequently, the Revenue filed an application for condonation of delay before the High Court, which has been accepted. In response to this development, Himatsingka Seide has proposed to file an appeal before the Supreme Court.
| Development: | Status |
|---|---|
| Appeals Filed By: | Revenue and the Company |
| Tribunal Outcome: | Appeal dismissed; additions of Rs. 6.90 crores deleted |
| Revenue's High Court Application: | Condonation of delay accepted |
| Company's Next Step: | Proposes to file appeal before the Supreme Court |
Settlement and Key Management Personnel
The company has confirmed that the litigation does not involve any key management personnel, promoters, or ultimate persons in control. Additionally, there has been no settlement of the proceedings, and accordingly, no terms of settlement, compensation, or penalty are applicable at this stage.
The disclosure was signed by Bindu D., Company Secretary and Compliance Officer of Himatsingka Seide Limited, from the company's registered office at No. 4/1-2, Crescent Road, Bangalore – 560001, India.
Historical Stock Returns for Himatsingka Seide
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| -1.59% | -3.73% | +4.24% | -28.62% | -43.09% | -47.09% |
If Himatsingka Seide files an appeal before the Supreme Court, how long could the litigation timeline extend, and what financial provisioning might the company need to make for the disputed Rs. 6.90 crores?
How could an unfavorable Supreme Court ruling on the transfer pricing adjustments impact Himatsingka Seide's future inter-company transaction structures with its subsidiaries and associated enterprises?
Are there other open transfer pricing disputes for assessment years beyond 2008-09 that could expose Himatsingka Seide to similar litigation risks and cumulative financial liabilities?


































