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, JUDGMENT WAS DELIVERED THEREIN AS UNDER:

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 12.09.2024 in IT(IT)A Nos.1412 to 1414/Bang/2024 on the file of the Income Tax Appellate Tribunal "C" Bench, Bengaluru [for short, 'the Tribunal']. The Tribunal's order is relevant to the Assessment Years 2015-16 to 2017-18. The question for consideration is: whether the assessee can be called upon to pay "royalty" for the transfer of software and related services.

This Court must observe that in the assessee's own case for the other relevant years, this question stands answered in favour of the assessee and the immediate reference could be made to the orders of this Court in W.P.No.120/2024 decided on

08.10.2025.

In the light of the afore, the appeal stands rejected.

Sd/-

(B M SHYAM PRASAD)

JUDGE Sd/-

(T.M.NADAF)

JUDGE RB