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AND 9 OTHERS RESERVED ON : 02.04.2026 PRONOUNCED ON: 28.08.2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28^TH DAY OF AUGUST, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND INCOME TAX APPEAL No.10 OF 2011 C/W INCOME TAX APPEAL No.23 OF 2011 INCOME TAX APPEAL No.24 OF 2011 INCOME TAX APPEAL No.44 OF 2015 INCOME TAX APPEAL No.128 OF 2015 INCOME TAX APPEAL No.469 OF 2015 INCOME TAX APPEAL No.492 OF 2016 Digitally signed INCOME TAX APPEAL No.514 OF 2016 by VINUTHA B S INCOME TAX APPEAL No.884 OF 2017 Location: H igh Court of Karnataka INCOME TAX APPEAL No.955 OF 2017 INCOME TAX APPEAL No.956 OF 2017 I.T APPEAL CROSS OBJECTION No.1 OF 2018 IN ITA No. 10/2011 BETWEEN:

1. SAP LABS INDIA PRIVATE LIMITED HAVING ITS OFFICE AT No.138, EXPORT PROMOTION INDUSTRIAL PARK, AND 9 OTHERS WHITEFIELD ROAD, WHITEFIELD, BANGALORE - 66.

…APPELLANT (BY SRI. D.D. NAGESHWAR RAO, ADVOCATE)

AND:

1. THE INCOME TAX OFFICER WARD-12(2), 14/3, 4^TH FLOOR, RASHTOTHANA BHAVAN (OPP. RBI)

NRUPATHUNGA ROAD, BANGALORE- 01 …RESPONDENT (BY SRI. N. VENKATARAMAN, ASG A/W SRI. E. I. SANMATHI, SENIOR STANDING COUNSEL A/W.

SRI. SUSHAL TIWARI & SRI. M. DILIP, STANDING COUNSEL)

THIS ITA IS FILED U/S.260-A OF I.T.ACT, 1961 ARISING OUT OF ORDER DATED 30-08-2010 PASSED IN ITA No.398/BANG/2008, FOR THE ASSESSMENT YEAR 2003-2004, PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN, ALLOW THE APPEAL AND SET ASIDE THE ORDER PASSED BY THE ITAT BANGALORE IN ITA No.398/BANG/2008, DATED 30-08-2010 (ANNEXURE-A), TO THE EXTENT PRAYED FOR, IN THE INTEREST OF JUSTICE AND EQUITY.

IN ITA No.23/2011 BETWEEN:

1. COMMISSIONER OF INCOME TAX C R BUILDINGS, (CENTRAL) QUEENS ROAD, BANGALORE - 560 001

2. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 12(3), BANGALORE ...APPELLANTS (BY SRI. N. VENKATARAMAN, ASG A/W SRI. E. I. SANMATHI, SENIOR STANDING COUNSEL A/W SRI. SUSHAL TIWARI & SRI. M. DILIP, STANDING COUNSEL)

AND 9 OTHERS AND:

1. M/S SAP INDIA PVT LTD No.138, EXPORT PROMOTION INDUSTRIAL PARK, WHITE FIELD, BANGALORE – 560 066 ...RESPONDENT (BY SRI. D.D. NAGESHWAR RAO, ADVOCATE)

THIS ITA IS FILED U/S.260-A OF I.T.ACT, 1961 ARISING OUT OF ORDER DATED 30/08/2010 PASSED IN ITA No.418/BANG/2008, FOR THE ASSESSMENT YEAR 2003-04, (ANNEXURE-A) PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN, SET ASIDE THE APPELLATE ORDER DATED 30/08/2010 PASSED BY THE ITAT, 'A' BENCH, BANGALORE, IN APPEAL PROCEEDINGS ITA No.418/BANG/2008 (ANNEXURE-A), AS SOUGHT FOR IN THIS APPEAL, IN THE INTEREST OF JUSTICE AND EQUITY.

IN ITA No.24/2011 BETWEEN:

1. COMMISSIONER OF INCOME TAX C R BUILDINGS, (CENTRAL)

QUEENS ROAD BANGALORE 560 001

2. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 12(3), BANGALORE ...APPELLANTS (BY SRI. N. VENKATARAMAN, ASG A/W SRI. E. I. SANMATHI, SENIOR STANDING COUNSEL A/W.

SRI. SUSHAL TIWARI & SRI. M. DILIP, STANDING COUNSEL)

AND:

1. M/S SAP INDIA PVT LTD No.138, EXPORT PROMOTION AND 9 OTHERS INDUSTRIAL PARK, WHITE FIELD, BANGALORE – 560 066 ...RESPONDENT (BY SRI. D.D. NAGESHWAR RAO, ADVOCATE)

THIS ITA IS FILED U/S.260-A OF I.T.ACT, 1961 ARISING OUT OF ORDER DATED 30/08/2010 PASSED IN ITA No.398/BANG/2008, FOR THE ASSESSMENT YEAR 2003-04 (ANNEXURE-A), PRAYING TO FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN, SET ASIDE THE APPELLATE ORDER DATED 30/08/2010 PASSED BY THE ITAT, 'A' BENCH, BANGALORE, IN APPEAL PROCEEDINGS ITA No.398/BANG/2008 (ANNEXURE-A), AS SOUGHT FOR IN THIS APPEAL, IN THE INTEREST OF JUSTICE AND EQUITY.

IN ITA No.44/2015 BETWEEN:

1. THE COMMISSIONER OF INCOME TAX C R BUILDING, QUEENS ROAD, BANGALORE – 560 001

2. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(2)

BANGALORE.

...APPELLANTS (BY SRI. N. VENKATARAMAN, ASG A/W SRI. E. I. SANMATHI, SENIOR STANDING COUNSEL A/W.

SRI. SUSHAL TIWARI & SRI. M. DILIP, STANDING COUNSEL)

AND:

1. M/S. BEARINGPOINT PROPERTY SERVICES PRIVATE LIMITED, (FORMERLY KNOWN AS BEARINGPOINT BUSINESS CONSULTING PRIVATE LTD)

SECOND FLOOR, EMBASSY IC