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. 672 OF 2023 BETWEEN:

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

2. THE DEPUTY COMMISSIONER OF INCOME TAX Digitally signed INTERNATIONAL TAXATION, by MADHUSHREE CIRCLE 1(2)

H Location: High KORAMANGALA, Court of BANGALORE Karnataka …APPELLANTS (BY SRI. E. I. SANMATHI, ADVOCATE)

AND:

1. M/S INFORMATICA LLC C/O INFORMATION BUSINESS SOLUTIONS PVT LTD, NO 66/1, BAGMANE COMMEZ 02, BAGMANE TECH PARK, C V RAMAN NAGAR, BANGALORE 560093 …RESPONDENT (BY MS. TANMAYEE RAJKUMAR., ADVOCATE)

THIS ITA/INCOME TAX APPEAL IS FIILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 05/08/2021 PASSED IN IT(TP)A NO.2867/BANG/2018, FOR THE ASSESSMENT YEAR 2015-2016 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 ORDER DATED 05/08/2021 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, A BENCH, BENGALURU, AS SOUGHT FOR, IN THE RESPONDENT-ASSESSEES CASE, IN A