- 1 - HC-KAR NC: 2025:KHC:52381-DB ITA No. 112 of 2024 C/W ITA No. 111 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 10TH DAY OF DECEMBER, 2025 PRESENT THE HON'BLE MR. JUSTICE B M SHYAM PRASAD AND THE HON'BLE MR. JUSTICE T.M.NADAF INCOME TAX APPEAL NO. 112 OF 2024 C/W INCOME TAX APPEAL NO. 111 OF 2024 IN ITA No. 112/2024 BETWEEN: 1. PR. COMMISSIONER OF INCOME TAX-3 BMTC COMPLEX, KORAMANGALA, BANGALORE. 2. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 59(1)(1), BANGALORE. …APPELLANTS (BY SRI. E.I. SANMATHI., ADVOCATE) AND: 1. M/S NVIDIA GRAPHICS PVT LTD NO C01, JACARANDA, Digitally Signed by REKHA R Location : High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:52381-DB ITA No. 112 of 2024 C/W ITA No. 111 of 2024 WING A, OUTER RING ROAD, MANYATHA EMBASSY BUSSINESS PARK, BENGALURU 560045. …RESPONDENT (BY MS.NIRANJANA., ADVOCATE FOR SMT. HEMA MURALIKRISHNA., ADVOCATE ) THIS INCOME TAX APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 31/08/2021 PASSED IN IT(TP)A NO. 801/BANG/2017 FOR THE ASSESSMENT YEAR 2011- 12, PRAYING TO SET ASIDE THE APPELLATE ORDER DATED 31/8/2021 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, C BENCH, BANGALORE IN APPEAL PROCEEDINGS NO. IT(TP)A NO. 801/BANG/2017 FOR ASSESSMENT YEAR 2011-12 (PRODUCED AS ANNEXURE A), AS SOUGHT FOR IN THIS APPEAL. IN ITA NO. 111/2024 BETWEEN: 1. PR. COMMISSIONER OF INCOME TAX-3 BMTC COMPLEX, KORAMANGALA, BANGALORE. - 3 - HC-KAR NC: 2025:KHC:52381-DB ITA No. 112 of 2024 C/W ITA No. 111 of 2024 2. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 59(1)(1), BANGALORE. ...APPELLANTS (BY SRI.E.I. SANMATHI., ADVOCATE) AND: M/S NVIDIA GRAPHICS PVT LTD, NO C1, JACARANDA, WING A, OUTER RING ROAD, MANYATHA EMBASSY BUSSINESS PARK, BENGALURU 560045 REP BY ITS DIRECTOR. ...RESPONDENT (BY MS.NIRANJANA., ADVOCATE FOR SMT. HEMA MURALIKRISHNA., ADVOCATE) THIS INCOME TAX APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961 ARISING OUT OF ORDER DATED: 31.08.2021 PASSED IN ITA NO. 736/BANG/2017 FOR ASSESSMENT YEAR 2011-12, PRAYING TO SET ASIDE THE APPELLATE ORDER DATED 31/8/2021 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, C BENCH, BANGALORE IN APPEAL PROCEEDINGS NO. ITA NO. 736/BANG/2017 FOR ASSESSMENT YEAR 2011-12 (PRODUCED AS ANNEXURE A), AS SOUGHT FOR IN THIS APPEAL. THESE APPEALS, COMING ON FOR FINAL HEARING, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: - 4 - HC-KAR NC: 2025:KHC:52381-DB ITA No. 112 of 2024 C/W ITA No. 111 of 2024 CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD and HON'BLE MR. JUSTICE T.M.NADAF ORAL JUDGMENT (PER: HON'BLE MR. JUSTICE B M SHYAM PRASAD) With both Mr.E.I.Sanmathi, the learned standing counsel for the appellants, and Ms.Niranjana, who appears on behalf of Ms.Hema Muralikrishna, the learned counsel for the respondent, stating that the appeals are rendered infructuous with the settlement under the 'Vivad se Vishwas Scheme', the appeals are disposed of accordingly. Sd/- (B M SHYAM PRASAD) JUDGE Sd/- (T.M.NADAF) JUDGE SA List No.: 1 Sl No.: 13