- 1 - NC: 2025:KHC:8030-DB ITA No. 419 of 2022 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF FEBRUARY, 2025 PRESENT THE HON'BLE MR JUSTICE KRISHNA S DIXIT AND THE HON'BLE MR JUSTICE G BASAVARAJA INCOME TAX APPEAL NO.419 OF 2022 BETWEEN: 1. THE COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, 4TH FLOOR, BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 095. 2. THE ASSISTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, CIRCLE-1(2), PRESENT ADDRESS DCIT, INTERNATIONAL TAXATION, CIRCLE-1(2), 4TH FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU - 560 095. …APPELLANTS (BY SRI. SANMATHI E I AND SRI. DILIP, ADVOCATES) AND: M/S. KENNAMETAL INC., C/O. KENNAMETAL INDIA, 8/9TH MILE, TUMKUR ROAD, BENGALURU - 560 073, PAN AACCK6397B …RESPONDENT (BY SRI. K.R. VASUDEVAN, ADVOCATE) THIS INCOME TAX APPEAL HAS FILED UNDER SEC .260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED Digitally signed by LAKSHMINARAYAN N Location: High Court of Karnataka - 2 - NC: 2025:KHC:8030-DB ITA No. 419 of 2022 16/02/2022 PASSED IN IT(IT)A NO.35/BANG/2021, FOR THE ASSESSMENT YEAR 2017-2018 PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, BENGALURU IN IT(IT)A NO. 35/BANG/2021 DATED 16/02/2022 FOR ASSESSMENT YEAR 2017-2018 ANNEXURE-C AND CONFIRM THE ORDER OF THE DRP COMMISSIONER CONFIRMING THE ORDER PASSED BY THE DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2), BENGLAURU, ETC. THIS APPEAL, COMING ON FOR ADMISSION, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: CORAM: HON'BLE MR JUSTICE KRISHNA S DIXIT and HON'BLE MR JUSTICE G BASAVARAJA ORAL JUDGMENT (PER: HON'BLE MR JUSTICE KRISHNA S DIXIT) The subject matter of this Appeal is substantially similar to the one this day decided by us in ITA No.418/2022 between THE COMMISSIONER OF INCOME TAX vs. M/S. KENNAMETAL INC. Like cases should be decided alike being adjudicatory norm, what has been - 3 - NC: 2025:KHC:8030-DB ITA No. 419 of 2022 ordered in the coordinate case would apply to this case also. Accordingly, this Appeal is also disposed off. Costs made easy. Sd/- (KRISHNA S DIXIT) JUDGE Sd/- (G BASAVARAJA) JUDGE DR List No.: 1 Sl No.: 0