IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8^TH 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. 135 OF 2024 BETWEEN:

1. PR COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)

KORAMANGALA BANGALORE

2. THE INCOME TAX OFFICER INTERNATIONAL TAXATION, BMTC COMPLEX, D igitally signed KORAMANGALA by BANGALORE MADHUSHREE H Location: High Court of …APPELLANTS Karnataka (BY SRI. E. I. SANMATHI, ADVOCATE)

AND:

M/S ALTAIR ENGINEERING INC 1820, EAST BIG BEAVER ROAD, TROY M1 999999 UNITED STATES, PAN AAICA 7762Q REP BY ITS DIRECTOR …RESPONDENT (BY SRI. K.K.CHYTHANYA, SENIOR ADVOCATE FOR SRI. TATA KRISHNA., ADVOCATE)

THIS ITA/INCOME TAX APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 4-12-2023 PASSED IN IT (IT)A NO.734/BANG/2023 FOR THE ASSESSMENT YEAR 2021-22 PRAYING TO 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 4/12/2023 PASSED BY THE INCOME TAX APPELLATE TRI8BUNAL, C BENCH, BANGALORE AS SOUGHT FOR, IN THE RESPONDENT-ASSESSEES CASE, IN APPEAL PROCE