IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA No. 842/Bang/2024 Assessment Years : 2014-15 The Dy. Commissioner of Income Tax, Vs. Cisco Systems (India) Pvt. Ltd., Circle – 2(1)(1), SEZ Unit, Bengaluru. Kadubeesanahalli Village, Bengaluru.

PAN – AABCC 0258 Q APPELLANT RESPONDENT Assessee by : Shri Nageswar Rao, Advocate Revenue by : Ms. Neera Malhotra, CIT (DR)

Date of hearing : 26.11.2024 Date of Pronouncement : 17.02.2025

O R D E R

PER WASEEM AHMED, ACCOUNTANT MEMBER:

This is an appeal filed by the Revenue against the order passed by the DCIT, Bengaluru dated 11/06/2024 for the assessment year

2014-15.

2. The Revenue has raised the following grounds of appeal; “The Ld. CIT(A) erred in facts and law in quashing the assessment order passed u/s 147 of the Income Tax Act, 1961, in the case of M/s Scientific Atlanta India Technology Pvt Ltd, predecessor to successor M/s Cisco Systems (India) Pvt Ltd.

The order passed by the CIT(A) is opposed to the ratio laid down in the Hon'ble Supreme Court judgement in the case of PC.IT(Central) v. Mahagdn Realtors (P) Ltd, [2022 SCC Online SC 407].”

3. The o