IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 29^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. 119 OF 2024 BETWEEN:

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

KORAMANGALA, BENGALORE

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

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

AND:

BLUE YONDER INC (FORMERLY KNOWN AS JDA SOFTWARE INC.)

C/O BLUE YONDER INDIA PVT LTD TOWER A MANTRI COMMERCIALS DEVARABEESANAHALLI OUTER RING ROAD, VARTHUR HOBLI, BENGALURU - 103.

REP BY ITS DIRECTOR …RESPONDENT (BY MS. TANMAYEE RAJKUMAR, ADVOCATE)

THIS ITA/INCOME TAX APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 03.01.2024 PASSED IN IT(IT)A NO. 424/BANG/2023 FOR THE ASSESSMENT YEAR 2019-20.

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 Reve