HC-KAR IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24^TH 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. 261 OF 2021 C/W INCOME TAX APPEAL No. 264 OF 2021 IN ITA No. 261/2021 BETWEEN:

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

2. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 4(2)(1), BMTC COMPLEX, KORMANGALA, Digitally signed BENGALURU.

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

Location:

HIGH COURT OF AND:

KARNATAKA M/S. YESHODA ELECTRICALS, NO.25, Y.NO.8/2, AMBALIPURA VILLAGE, SARJAPURA ROAD, BENGALURU - 560 034 PAN. AAAFY0757E …RESPONDENT (BY SMT. KRISHIKA VAISHNAV, ADVOCATE FOR SRI. A.MAHESH CHOWDHARY, ADVOCATE)

HC-KAR THIS ITA IS FILED UNDER SECTION 260A OF THE INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 03.02.2021 PASSED IN ITA No.1176/BANG/2016, FOR THE ASSESSMENT YEAR 2007-2008, PRAYING TO DECIDE THE FOREGOIND QUESTION OF LAW AND OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE HON'BLE COURT AS DEEMED FIT. SET ASIDE THE APPELLATE ORDER DATED 03.02.2021 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, 'C' BEN