- 1 - HC-KAR NC: 2025:KHC:48243-DB RP No. 608 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 21ST DAY OF NOVEMBER, 2025 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE C.M. POONACHA REVIEW PETITION NO. 608 OF 2024 BETWEEN: 1. THE PR. COMMISSIONER OF INCOME TAX -1 BMTC COMPLEX, KORAMANGALA, BANGALORE-560 095. 2. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(1), BMTC COMPLEX, KORAMANGALA, BANGALORE-560 095. …PETITIONERS (BY SRI. Y V RAVIRAJ, ADVOCATE) AND: M/S ALLSTATE INDIA PVT LTD 7TH FLOOR, BUILDING NO.1, RMZ ECO WORLD, BELLANDUR S/O. DEVARABESANHALLI, VARTHUR HOBLI, BANGALORE-560 103. REP. BY ITS MANAGING DIRECTOR. …RESPONDENT THIS REVIEW PETITION IS FILED UNDER ORDER 47 RULE 1 R/W SEC. 114 OF CPC, 1908, PRAYING TO REVIEW THE ORDER DATED 12.08.2024 PASSED BY THIS HONBLE COURT IN ITA NO. 669/2023. Digitally signed by NIRMALA DEVI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:48243-DB RP No. 608 of 2024 THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.G.PANDIT and HON'BLE MR. JUSTICE C.M. POONACHA ORAL ORDER (PER: HON'BLE MR. JUSTICE S.G.PANDIT) 1. This review petition filed under Order XLVII Rule 1 read with Section 114 of the Code of Civil Procedure, 19081 is directed against the judgment dated 12.08.2024 passed in ITA No.669/2023, whereunder this Court disposed of the appeal following the Full Bench decision of this Court in CIT v. Hewiett Packard Soft Limited, reported in (2017) 87 taxmann.com 182. 2. Learned counsel for the review petitioner would submit that the above said decision is pending consideration before the Apex Court in SLP Diary No.27642/2018. Therefore, it is his submission that the review petitioner shall be given liberty to revive the appeal in case the decision of the Apex Court in the above pending SLP is in favour of the review petitioner. 1 hereinafter referred to as 'CPC' - 3 - HC-KAR NC: 2025:KHC:48243-DB RP No. 608 of 2024 3. The above submission of the learned counsel for the review petitioner appears to be reasonable and it is observed that in case the revenue succeeds in the SLP pending before the Apex Court in SLP Diary No.27642/2018 (supra), liberty is reserved to the review petitioner/revenue to revive ITA No.669/2023. 4. Accordingly, the review petition is disposed of. 5. Pending applications stand disposed of. Sd/- (S.G.PANDIT) JUDGE Sd/- (C.M. POONACHA) JUDGE ND List No.: 1 Sl No.: 23