PR. COMMISSIONER OF INCOME TAX vs. M/S SYNAMEDIA LIMITED

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ITA/106/2024HC KarnatakaKAHC01013630202406 August 2026Bench: S.G.PANDIT,K.MANMADHA RAO4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court dismissed the appeal filed by the Revenue. The Court observed that the common order passed by the ITAT, which is under challenge in the present appeal for AY 2013-14, was also the subject matter of ITA No.109/2024 for AY 2012-13. In that previous appeal, the High Court had dismissed the Revenue's appeal by following the judgment of the Hon'ble Apex Court in the case of Engineering Analysis Centre of Excellence Private Limited vs. Commissioner of Income-Tax and Another (2021) 432 ITR 471. Therefore, following the order passed in ITA No.109/2024 between the same parties for the assessment year 2012-13, the present appeal for AY 2013-14 was also dismissed. The operative direction is the dismissal of the appeal. No issue was expressly left undecided.

What were the facts?

The appeal is filed by the Pr. Commissioner of Income Tax (International Taxation) and the Assistant Commissioner of Income Tax, International Taxation, Bangalore (collectively referred to as 'Revenue') against the order dated 12.11.2021 passed by the Income Tax Appellate Tribunal (ITAT), Bengaluru. The assessment year in question is 2013-14. The ITAT's order was in appeal proceedings bearing IT(IT)A No.505/Bang/2017. The Revenue is challenging the ITAT's decision. The High Court notes that a similar common order passed by the ITAT in IT(IT)A No.505/Bang/2017 for assessment year 2012-13 was challenged in ITA No.109/2024. That appeal was dismissed by following the Supreme Court's judgment in Engineering Analysis Centre of Excellence Private Limited vs. Commissioner of Income-Tax and Another.

What were the issues?

1. Whether the High Court should decide the question of law and/or other questions of law as deemed fit by the Court, and set aside the appellate order dated 12.11.2021 passed by the ITAT, Bengaluru, in the respondent-assessee's case for AY 2013-14. The Revenue's contention is that the ITAT's order dated 12.11.2021 for AY 2013-14 should be set aside. The Revenue relies on the fact that a similar order for AY 2012-13, arising from the same ITAT appeal number (IT(IT)A No.505/Bang/2017), was dismissed by the High Court in ITA No.109/2024. This dismissal was based on the Supreme Court's decision in Engineering Analysis Centre of Excellence Private Limited vs. Commissioner of Income-Tax and Another (2021) 432 ITR 471. The Assessee's contention is not explicitly recorded in terms of arguments presented, but their counsel is appearing for the respondent. The judgment indicates the assessee is supporting the ITAT's order.

Which sections of the Income-tax Act were involved?

Section 260-A

AI-generated summary — verify with the full judgment below

HC-KAR IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 6TH DAY OF AUGUST, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE DR. JUSTICE K.MANMADHA RAO INCOME TAX APPEAL NO. 106 OF 2024 BETWEEN:

1.

PR. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) KORAMANGALA, BANGALORE.

2.

THE ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAX, INTERNATIONAL TAXATION, CIRCLE 1(2), KORMANGALA, BANGALORE. …APPELLANTS (BY SRI. E I SANMATHI & SRI NIRMAL MATHEW, ADV.)

AND:

M/S. SYNAMEDIA LIMITED (FORMERLY KNOWN AS NDS LIMITED) BLOCK, NO.9A AND 9B PRINTECH PARK, SURVEY NO.51-64/4, SARJAPUR OUTER RING ROAD, BELLANDUR VILLAGE, BENGALURU-560103 PAN. AABCN2524L. …RESPONDENT (BY MS. MANASA ANANTHAN, ADV. FOR MS. TANMAYEE RAJKUMAR, ADV.)

Digitally signed by NANJUNDACHARI Location: High Court of Karnataka HC-KAR THIS APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 12/11/2021 PASSED IN IT(IT)A NO.505/BANG/2017 FOR THE ASSESSMENT YEAR 2013-14, PRAYING TO 1). DECIDE THE FOREGOING QUESTION OF LAW AND/OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE COURT AS DEEMED FIT AND SET ASIDE THE APPELLATE ORDER DATED 12/11/2021 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, ‘B’ BENCH, BANGALORE, AS SOUGHT FOR, IN THE RESPONDENT- ASSESSEE’S CASE, IN APPEAL PROCEEDINGS IN IT(IT)A NO.505/BANG/2017 FOR A.Y 2013-14 (ANNEXURE-A) AND GRANT SUCH OTHER RELIEF AS DEEMED FIT, IN THE INTEREST OF JUSTICE.

THIS APPEAL, COMING ON FOR ORDERS, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE S.G.PANDIT AND HON'BLE DR. JUSTICE K.MANMADHA RAO

ORAL JUDGMENT (PER: HON'BLE MR. JUSTICE S.G.PANDIT)

Heard learned counsel Sri.E.I.Sanmathi for appellants/Revenue and learned counsel Ms. Manasa Ananthan for Ms. Tanmayee Rajkumar for respondent/assessee. Perused the appeal papers.

2.

The above appeal is filed under Section 260A of the Income Tax Act, 1961 questioning common order HC-KAR dated 12.11.2021 in IT(IT)A.No.505/Bang/2017 for the assessment year 2013-14 passed by the Income Tax Appellate Tribunal, ‘B’ Bench, Bengaluru (for short, ‘the Tribunal’).

3.

During the course of hearing, it is brought to our notice that the common order passed by the Tribunal was the subject matter of ITA.No.109/2024 wherein the common order passed in IT(IT)A.No.505/Bang/2017 for the assessment year 2012-13 was under challenge and the appeal was dismissed by following the judgment of the Hon'ble Apex Court in the case of ENGINEERING ANALYSIS CENTRE OF EXCELLENCE PRIVATE LIMITED VS. COMMISSIONER OF INCOME-TAX AND ANOTHER

(2021) 432 ITR 471.

4.

Since the common order passed by the Tribunal is already upheld, we dismiss the present appeal, following the order passed in ITA.No.109/2024 dated 19.08.2025 HC-KAR between the same parties for the assessment year 2012-13.

5.

In view of dismissal of the appeal, I.A.No.1/2026 stands disposed of.

Sd/- (S.G.PANDIT) JUDGE

Sd/- (DR.K.MANMADHA RAO) JUDGE

NC CT:bms List No.: 1 Sl No.: 9

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