IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 23^RD DAY OF SEPTEMBER, 2025 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND INCOME TAX APPEAL No. 289 OF 2021 BETWEEN:

1. PR. COMMISSIONER OF INCOME TAX-2, BMTC COMPLEX, KORAMANGALA, BANGALORE.

2. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -4 (1) (1), BENGALURU.

…APPELLANTS Digitally signed by VALLI MARIMUTHU (BY SRI SANMATHI E I., SENIOR STANDING COUNSEL)

Location:

HIGH COURT OF AND:

KARNATAKA

1. M/S KARNATAKA POWER CORPORATION LIMITED, No.82 SHAKTHI BHAVAN, RACE COURSE ROAD, BENGALURU-560001.

…RESPONDENT (BY SRI A. SHANKAR, SENIOR ADVOCATE FOR SRI ANNAMALAI S., ADVOCATE)

THIS ITA/ INCOME TAX APPEAL IS FILED UNDER SECTION 260-A OF INCOME TAX ACT 1961 ARISING OUT OF ORDER DATED 11.01.2021 PASSED IN ITA No.282/BANG/2017, FOR THE ASSESSMENT YEAR 2002-2003 PRAYING TO DECIDE THE FOREGOING QUESTION OF LAW AS MAY BE FORMULATED BY THE HON'BLE COURT AS DEEMED FIT. SET ASIDE THE APPELLATE ORDER DATED 11.01.2021 PASSED BY THE INCOMETAX APPELLATE TRIBUNAL 'A' BENCH, BENGALURU, AS SOUGHT FOR, IN THE RESPONDENT - ASSESSEE'S CASE IN APPEAL PROCEEDINGS No.282/BANG/2017 (ANNEXURE-A) , FOR THE ASSESSMENT YE