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HC-KAR NC: 2025:KHC:47645-DB ITA No. 108 of 2024 C/W ITA No. 176 of 2024 ITA No. 179 of 2024 AND 2 OTHERS
IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 19TH DAY OF NOVEMBER, 2025 PRESENT THE HON'BLE MR. JUSTICE B M SHYAM PRASAD AND THE HON'BLE MR. JUSTICE T.M.NADAF INCOME TAX APPEAL NO. 108 OF 2024 C/W INCOME TAX APPEAL NO. 176 OF 2024 INCOME TAX APPEAL NO. 179 OF 2024 INCOME TAX APPEAL NO. 192 OF 2024 INCOME TAX APPEAL NO. 201 OF 2024
IN ITA No. 108/2024
BETWEEN:
PR. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) KORAMANGALA, BANGALORE.
THE ASSISTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAX, INTERNATIONAL TAXATION, CIRCLE 1(2) KORMANGALA, BANGALORE. …APPELLANTS (BY SRI. E.I. SANMATHI INDRAKUMAR., ADVOCATE)
Digitally Signed by REKHA R Location : High Court of Karnataka
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HC-KAR NC: 2025:KHC:47645-DB ITA No. 108 of 2024 C/W ITA No. 176 of 2024 ITA No. 179 of 2024 AND 2 OTHERS
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
…RESPONDENT (BY Ms. TANMAYEE RAJKUMAR., ADVOCATE)
THIS INCOME TAX 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.255/BANG/2014, FOR THE ASSESSMENT YEAR 2010-2011 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- ASSESSEES CASE, IN APPEAL PROCEEDINGS IN IT(IT)A NO. 255/BANG/2014 FOR A.Y.2010-11 (ANNEXURE-A).
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HC-KAR NC: 2025:KHC:47645-DB ITA No. 108 of 2024 C/W ITA No. 176 of 2024 ITA No. 179 of 2024 AND 2 OTHERS
IN ITA NO. 176/2024
BETWEEN:
PR. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) KORAMANGALA, BANGALORE.
THE DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, CIRCLE 1(2), KORAMANGALA, BANGALORE.
...APPELLANTS (BY SRI. SANMATHI E I., ADVOCATE)
AND:
M/S SYNAMEDIA INDIA PVT LTD REP BY ITS DIRECTOR BLOCK NO.9A AND 9B, 7TH FLOOR, PRINTECH PARK, SURVEY NO.51-64/4, SARJAPUR OUTER RING ROAD, BELLANDUR VILLAGE, BENGALURU-560103.
...RESPONDENT (BY Ms. TANMAYEE RAJKUMAR., ADVOCATE)
THIS INCOME TAX APPEAL IS FILED UNDER SEC. 260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 25/01/2024 PASSED IN IT(TP)A NO.1046/BANG/2023, FOR THE ASSESSMENT YEAR
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HC-KAR NC: 2025:KHC:47645-DB ITA No. 108 of 2024 C/W ITA No. 176 of 2024 ITA No. 179 of 2024 AND 2 OTHERS
2016-2017 PRAYING TO 1 DECIDE THE FOREGOING QUESTION OF LAW AND / OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE HONBLE COURT AS DEEMED FIT AND SET ASIDE THE APPELLATE ORDER DATED 25/1/2024 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, A BENCH, BANGALORE, AS SOUGHT FOR, IN THE RESPONDENT- ASSESSEES CASE, IN APPEAL PROCEEDINGS IN IT (IT)A NO. 1046/BANG/2023 FOR A.Y. 2016-17 ANNEXURE-A.
IN ITA NO. 179/2024
BETWEEN:
PR. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) KORAMANGALA, BANGALORE.
THE DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, CIRCLE 1(2), KORAMANGALA, BANGALORE.
...APPELLANTS (BY SRI.E.I. SANMATHI., ADVOCATE)
AND:
M/S SYNAMDEIA INDIA PVT LTD REP BY ITS DIRECTOR BLOCK NO.9A AND 9B, 7TH FLOOR, PRINTECH PARK, SURVEY NO.51-64/4, SARJAPUR OUTER RING ROAD, BELLANDUR VILLAGE, BENGALURU-560103.
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HC-KAR NC: 2025:KHC:47645-DB ITA No. 108 of 2024 C/W ITA No. 176 of 2024 ITA No. 179 of 2024 AND 2 OTHERS
...RESPONDENT (BY Ms. TANMAYEE RAJKUMAR., ADVOCATE)
THIS INCOME TAX APPEAL IS FILED UNDER SEC 260 A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 25/01/2024 PASSED IN IT A NO.1024/BANG/2023, FOR THE ASSESSMENT YEAR 2015-2016 PRAYING TO 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 25/1/2024 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, A BENCH, BANGALORE, AS SOUGHT FOR, IN THE RESPONDENT-ASSESSEES CASE, IN APPEAL PROCEEDINGS IN IT (IT) A NO. 1024/BANG/2023 FOR A.Y. 2015-16 ANNEXURE A.
IN ITA NO. 192/2024
BETWEEN:
PR. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) KORAMANGALA, BANGALORE.
THE DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, CIRCLE 1(2), KORAMANGALA, BANGALORE. ...APPELLANTS (BY SRI. SANMATHI E I., ADVOCATE)
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HC-KAR NC: 2025:KHC:47645-DB ITA No. 108 of 2024 C/W ITA No. 176 of 2024 ITA No. 179 of 2024 AND 2 OTHERS
AND:
M/S SYNAMEDIA INDIA PVT LTD REPRESENTED BY ITS DIRECTOR BLOCK NO.9A AND 9B, 7TH FLOOR, PRINTECH PARK, SURVEY NO.51-64/4, SARJAPUR OUTER RING ROAD, BELLANDUR VILLAGE, BENGALURU-560103.
...RESPONDENT (BY Ms. TANMAYEE RAJKUMAR., ADVOCATE)
THIS INCOME TAX APPEAL IS FILED UNDER SEC. 260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 25.1.2024 PASSED IN ITA NO.1025/BANG/2023, FOR THE ASSESSMENT YEAR 2017-18. PRAYING TO 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 25/1/2024 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, A BENCH, BANGALORE, AS SOUGHT FOR, IN THE RESPONDENT- ASSESSEES CASE, IN APPEAL PROCEEDINGS IN IT(IT)A NO. 1025/BANG/2023 FOR A.Y. 2017-18 (ANNEXURE- A).
IN ITA NO. 201/2024
BETWEEN:
PR. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)
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HC-KAR NC: 2025:KHC:47645-DB ITA No. 108 of 2024 C/W ITA No. 176 of 2024 ITA No. 179 of 2024 AND 2 OTHERS
KORAMANGALA, BANGALORE.
THE DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, CIRCLE 1(2), KORAMANGALA, BANGALORE.
...APPELLANTS (BY SRI. SANMATHI E I., ADVOCATE)
AND:
M/S SYNAMEDIA INDIA PVT LTD REP BY ITS DIRECTOR BLOCK NO.9A AND 9B, 7TH FLOOR, PRINTECH PARK, SURVEY NO.51-64/4, SARJAPUR OUTER RING ROAD, BELLANDUR VILLAGE, BENGALURU-560103 ...RESPONDENT (BY Ms. TANMAYEE RAJKUMAR., ADVOCATE)
THIS INCOME TAX APPEAL IS FILED UNDER SEC 260A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 25.01.2024 PASSED IN IT(IT) A NO.1023/BANG/2023, FOR THE ASSESSMENT YEAR 2014-2015 PRAYING TO DECIDE THE FOREGOING QUESTION OF LAW AND OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE COURT AS DEEMD FIT AND SET ASIDE THE APPELLATE ORDER DATED 25.01.2024 PASSED BY INCOME TAX APPELLATE TIBUNAL 'A' BENCH, BANGALORE, AS SOUGHT FOR, IN THE RESPONDENT- ASSESSE'S CASE IN APPEAL PROCEEDINGS IN IT (IT) A NO. 1023/BANG/2023 FOR AY 2014-15 (ANNEXURE-A).
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HC-KAR NC: 2025:KHC:47645-DB ITA No. 108 of 2024 C/W ITA No. 176 of 2024 ITA No. 179 of 2024 AND 2 OTHERS
THESE APPEALS, COMING ON FOR ADMISSION, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD and HON'BLE MR. JUSTICE T.M. NADAF
ORAL JUDGMENT
(PER: HON'BLE MR. JUSTICE B M SHYAM PRASAD)
The Revenue has filed these appeals calling in question the Income Tax Appellate Tribunal's common orders dated 12.11.2021 and 25.01.2024. The Income Tax Appellate Tribunal is referred to as ‘the Tribunal’, and the details of the appeals with the Tribunal and the corresponding present appeals are as follows: The Appeal with the Tribunal The Assessment Year The Tribunal’s Order The Appeal with this Court IT[IT]A 255/Bang/2014 2010 - 11 Order dated 12.11.2021 ITA 108/2024 IT[IT]A 1046/Bang/2023 2016 - 17 Order dated 25.01.2024 ITA 176/2024 IT[IT]A 1024/Bang/2023 2015 - 16 Order dated 25.01.2024 ITA 179/2024 IT[IT]A 1025/Bang/2023 2017 – 18 Order dated 25.01.2024 ITA 192/2024
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HC-KAR NC: 2025:KHC:47645-DB ITA No. 108 of 2024 C/W ITA No. 176 of 2024 ITA No. 179 of 2024 AND 2 OTHERS
IT[IT]A 1023/Bang/2023 2014 - 16 Order dated 25.01.2024 ITA 201/2024
If the Revenue’s first of the present appeals in ITA No.108/2024 is against a foreign entity, the other appeals are against its associated Indian Enterprise. The Tribunal, by the impugned common order dated 25.01.2024, has dismissed the Revenue’s appeals based on its order dated 13.12.2023 in IT[IT]A/940/Bang/2023. The Revenue's appeal in ITA No.113/2025 against this order dated 13.12.2023 is dismissed by this Court on 10.09.2025. The Tribunal's common order dated 12.11.2021 is also brought before this Court in ITA No.107/2024, and this Court has disposed of this appeal on 20.08.2025 in view of the opinion in ITA No.698/2023.
It is thus obvious that the Revenue's appeals against the Tribunal's order on similar issues have been disposed of by this Court in the appeals referred to above based on the decision of the Apex Court in
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HC-KAR NC: 2025:KHC:47645-DB ITA No. 108 of 2024 C/W ITA No. 176 of 2024 ITA No. 179 of 2024 AND 2 OTHERS
Engineering Analysis Centre of Excellence Private Limited v. Commissioner of Income Tax And Another [reported in (2021) 432 ITR 471]. It is not in dispute that certain review petitions, which are filed asserting that a review petition as against the decision in Engineering Analysis Centre of Excellence Private Limtied [supra] is pending, are disposed of. In the light of these circumstances, this Court opines that none of the questions proposed are open for consideration and the appeals must be rejected. The appeals are rejected accordingly.
Sd/- (B M SHYAM PRASAD) JUDGE
Sd/- (T.M.NADAF) JUDGE
SA ct:sr