IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 12^TH DAY OF AUGUST, 2025 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND INCOME TAX APPEAL NO. 698 OF 2023 BETWEEN:

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

2. THE DY. COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, CIRCLE 1(2), KORAMANGALA, BANGALORE.

…APPELLANTS (BY SRI. SANMATHI E. I., ADV.)

AND:

M/S. SYNAMEDIA LIMITED (FORMERLY KNOWN AS NDS LIMITED), Digitally signed BLOCK NO.9A AND 9 B, by VALLI MARIMUTHU PRITECH PARK, SURVEY NO.51-64/4, SARJAPUR OUTER RING ROAD, Location: HIGH COURT OF BELLANDUR VILLAGE, KARNATAKA BENGALURU-560103 PAN: AABCN 2524L …RESPONDENT (BY SRI. T. SURYANARAYANA, SR. ADV. FOR SMT. TANMAYEE RAJKUMAR, ADV.)

THIS APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT

1961, ARISING OUT OF ORDER DATED 14/02/2022 PASSED IN ITA NO. 3350/BANG/2018, FOR THE ASSESSMENT YEAR 2014-15, PRAYING TO DECIDE THE FOREGOING QUESTION OF LAW AND/OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE HON’BLE COURT AS DEEMED FIT AND SET ASIDE THE APPELLATE ORDER DATED 14.02.2022 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH, BANGALORE,