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 Revenue and the assessee have been in dispute on whether the receipts by the assessee for sale of software and services associated with such software would be "Royalty". The dispute as regards the latter being "Royalty" stands concluded with this Court's order dated 08.10.2025 in ITA No.120/2024 in view of the decision of the Apex Court in Engineering Analysis Centre of Excellence Private Limited Vs. Commissioner of Income Tax and Another reported in AIR 2021 SC 124 The dispute in the present case relates to the sale of software and it is undisputed that the decision of the Apex Court in Engineering Analysis Centre of Excellence Private Limited [supra] would apply to the present case as well. As such, this appeal also stands dismissed.

Sd/-

(B M SHYAM PRASAD)

JUDGE Sd/-

(T.M.NADAF)

JUDGE RB