- 1 - NC: 2025:KHC:431-DB ITA No. 9 of 2024 C/W ITA No. 5 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF JANUARY, 2025 PRESENT THE HON'BLE MR JUSTICE KRISHNA S DIXIT AND THE HON'BLE MR JUSTICE G BASAVARAJA INCOME TAX APPEAL NO. 9 OF 2024 C/W INCOME TAX APPEAL NO. 5 OF 2024 IN ITA No. 9/2024: BETWEEN: 1. THE COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, 4TH FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU 560 095. 2. THE DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(2) 4TH FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU 560 095. …APPELLANTS (BY SRI. Y V RAVIRAJ., ADVOCATE AND SRI. DILIP M.,ADVOCATE) AND: M/S BELGACOM INTERNATIONAL CARRIER SERVICES SA, BOULEVARD DU ROI ALTER II, 27, 1030 BRUSSELS, BELGUIM - 271 030. PAN: AAJCB5259J …RESPONDENT (BY SRI. RAVI RAGHAVAN.,ADVOCATE AND MS. NEHA SHARMA., ADVOCATE) Digitally signed by SHARADA VANI B Location: HIGH COURT OF KARNATAKA - 2 - NC: 2025:KHC:431-DB ITA No. 9 of 2024 C/W ITA No. 5 of 2024 THIS ITA / INCOME TAX APPEAL UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 29/08/2023 PASSED IN IT(IT)A No.197/BANG/2023, FOR THE ASSESSMENT YEAR 2014-2015 PRAYING TO 1) FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN AND 2) ALLOW THE APPEAL AND SET ASIDE THE ORDERS PASSED BY THE INCOME-TAX APPELLATE TRIBUNAL, BENGALURU IN IT(IT)A NO. 197/BANG/2023 DATED 29.08.2023 FOR ASSESSMENT YEAR 2014-2015 ANNEXURE A AND CONFIRM THE ORDER OF the DRP CONFIRMING THE ORDER PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE -2(2), BENGALURU AND ETC., IN ITA NO. 5/2024: BETWEEN: 1. THE COMMISSIONER OF INCOME-TAX INTERNATIONAL TAXATION, 4TH FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU 560 095. 2. THE DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(2), 4TH FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU 560 095. ...APPELLANTS (BY SRI. Y V RAVIRAJ., ADVOCATE AND SRI. DILIP M.,ADVOCATE) AND: 1. M/S BELGACOM INTERNATIONAL CARRIER SERVICES SA, BOULEVARD DU ROI ALTER II, 27, 1030 BRUSSELS, BELGUIM - 271 030. PAN: AAJCB5259J ...RESPONDENT (BY MS.NEHA SHARMA.,ADVOCATE) - 3 - NC: 2025:KHC:431-DB ITA No. 9 of 2024 C/W ITA No. 5 of 2024 THIS ITA / INCOME TAX APPEAL UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 29/08/2023 PASSED IN IT(IT)A NO.198/BANG/2023, FOR THE ASSESSMENT YEAR 2015-2016, PRAYING TO I. FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW STATED THEREIN AND II. ALLOW THE APPEAL AND SET ASIDE THE ORDERS PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, BENGALURU IN IT(IT)A NO. 198/BANG/2023 DATED 29/08/2023 FOR ASSESSMENT YEAR 2015-2016 ANNEXURE-A AND CONFIRM THE ORDER OF THE DRP CONFIRMING THE ORDER PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-2(2), BENGALURU AND ETC., THESE INCOME TAX APPEALS COMING ON FOR ORDERS THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: CORAM: HON'BLE MR JUSTICE KRISHNA S DIXIT and HON'BLE MR JUSTICE G BASAVARAJA ORAL JUDGEMENT (PER: HON'BLE MR JUSTICE KRISHNA S DIXIT) Learned counsel appearing for both the sides in all fairness submit that the subject matter of these cases is substantially similar to the one in VODAFONE IDEA LTD., vs. DEPUTY DIRECTOR OF INCOME-TAX, (INTERNATIONAL TAXATION), [2023] 152 taxmann.com 575 (Karnataka) disposed off by a Coordinate Bench of this Court vide order dated 14.07.2023 and therefore, the relief granted to the - 4 - NC: 2025:KHC:431-DB ITA No. 9 of 2024 C/W ITA No. 5 of 2024 Appellant – Assessee therein needs to be extended to the similarly circumstanced Respondent-Assessee in these Appeals too. Ordered accordingly and the Appeals are disposed off, costs having been made easy. Sd/- (KRISHNA S DIXIT) JUDGE Sd/- (G BASAVARAJA) JUDGE Bsv List No.: 1 Sl No.: 12