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HC-KAR NC: 2025:KHC:39640-DB ITA No. 136 of 2024
IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF OCTOBER, 2025 PRESENT THE HON'BLE MR. JUSTICE B M SHYAM PRASAD AND THE HON'BLE MR. JUSTICE T.M.NADAF INCOME TAX APPEAL NO. 136 OF 2024
BETWEEN:
THE PR. COMMISSIONER OF INCOME TAX -3 BANGALORE
THE JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-3 BENGALURU
…APPELLANTS (BY SRI. E.I. SANMATHI, ADVOCATE)
AND:
M/S GOOGLE INDIA PVT LTD., NO.3, RMZ INFINITY TOWER-E, 4th FLOOR, OLD MADRAS ROAD, BANGALROE 560016
Digitally signed by MADHUSHREE H Location: High Court of Karnataka
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HC-KAR NC: 2025:KHC:39640-DB ITA No. 136 of 2024
PAN AACCG5027D
…RESPONDENT (BY SRI. ANMOL ANAND, ADVOCATE FOR SRI. MRINAL SHANKAR, ADVOCATE)
THIS ITA / Income Tax Appeal IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 31-10-2023 PASSED IN M.P.NO.201/BANG/2023 FOR A.Y. 2015- 16 (ANNEUXRE-A) FOR THE ASSESSMENT YEAR 2015-16. PRAYING THAT THIS HONBLE COURT BE PLEASED A)DECIDE THE FOREGOING QUESTION OF LAW AND / OR SUCH OTHER QUESTIONS OF LAW AS MAYBE FORMULATED BY THE HONBLE COURT AS DEEMED FIT AND SET ASIDE THE APPELLATE ORDER DATED 31.10.2023 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, C BENCH, BANGALORE, AS SOUGHT FOR, IN THE RESPONDENT-ASSESSEES CASE, IN APPEAL PROCEEDINGS IN M.P.NO.,201/BANG/20213 FOR A.Y.2015-16(ANNEXURE-A)
THIS APPEAL, COMING ON FOR ADMISSION, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER:
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HC-KAR NC: 2025:KHC:39640-DB ITA No. 136 of 2024
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 is in appeal as against the order dated 31.10.2023 in M.P.No.201/Bang/2023 (in IT(TP)A No.2301/Bang/2019) on the file of the Income Tax Appellate Tribunal "C" Bench, Bengaluru [for short, 'the Tribunal']. This order is relevant to the Assessment Year 2015-16 and is based on the Tribunal's orders in the assessee's sister concern which are relevant to the Assessment Years 2010-11 and 2012-13.
The Tribunal's order relevant to these years in IT(IT)A No.167/Bang/2021 and IT(IT)A No.688/Bang/2022 are called in question before this Court in ITA No.653/2023 c/w ITA No.657/2023, and this Court has disposed of these appeals observing that the proposed substantial questions of
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HC-KAR NC: 2025:KHC:39640-DB ITA No. 136 of 2024
law are answered by a Co-ordinate Bench of this Court in the Deputy Commissioner of Income Tax (International Taxation) Vs. Flipkart Internet (P) Ltd. reported in (2025) 171 Taxmann.com 693 (Karnataka).
Mr. E.I. Sanmathi, the learned Senior standing counsel for the Revenue, and Mr. Anmol Anand, the learned counsel who appears for the respondent, are heard. The appeal stands disposed of in the light of the afore.
Sd/- (B M SHYAM PRASAD) JUDGE
Sd/- (T.M.NADAF) JUDGE