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. 69 OF 2025 BETWEEN:

1. PR.COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)

KORMANGALA BANGALORE

2. THE ASSISTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE1(2) D igitally signed KORMANGALA by BANGALORE. MADHUSHREE H Location: High Court of …APPELLANTS Karnataka (BY SRI. E. I. SANMATHI, ADVOCATE)

AND:

M/S BLUE YONDER INC TOWER A MANTRI COMMERCIALS DEVARABEESANAHALLI OUTER RING ROAD VARTHUR HOBLI BANGALORE 103 PAN AACCJ3581C …RESPONDENT (BY MS. TANMAYEE RAJKUMAR, ADVOCATE)

THIS ITA/INCOME TAX APPEAL IS FILED UNDER SEC. 260-A OF INCOME TAX ACT 1961 PRAYING TO 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 COURT ORDER DATED 12.09.2024 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, C BENCH, BANGALORE, AS SOUGHT FOR, INT HE RESPONDENT- ASSESSEES CASE, IN APPEAL PROCEEDINGS IN IT(IT)A NO.1414/BANG/2024 FOR AY.2017-18 (ANNEXURE-

A).

THIS APPEAL, COMING ON FOR ADMISSION, THIS DAY, JUDGMEN