- 1 - HC-KAR NC: 2026:KHC:14907 WP No. 27816 of 2024 C/W WP No. 27815 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 12TH DAY OF MARCH, 2026 BEFORE THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV WRIT PETITION NO. 27816 OF 2024 (T-IT) C/W WRIT PETITION NO. 27815 OF 2024 (T-IT) IN WP No. 27816/2024 BETWEEN: 1. CA (INDIA) TECHNOLOGIES PVT LTD., S1, WIPRO ELECTRONIC CITY, SPECIAL ECONOMIC ZONE, DODDATHOGUR VILLAGE, BEGUR HOBLI, ELECTRONIC CITY, BANGALORE - 560 100. REPRESENTED HEREIN BY ITS DIRECTOR PAN NO. AAACC4971D …PETITIONER (BY SMT. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME-TAX, TRANSFER PRICING, DC/ACIT TP 1 (1)(2), BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE - 560 095. 2. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 2(2)(1), BMTC BUILDING, 6TH BLOCK, Digitally signed by VIJAYA P Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:14907 WP No. 27816 of 2024 C/W WP No. 27815 of 2024 80 FEET ROAD, KORAMANGALA, BANGALORE - 560 095. …RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ORDER DATED 19.09.2024 (ANNEXURE-G) BEARING DIN ITBA/COM/F/17/2024-25/1068846231(1) PASSED BY THE 1ST RESPONDENT FOR THE ASSESSMENT YEAR 2017-18 AND ETC. IN WP NO. 27815/2024 BETWEEN: 1. CA (INDIA) TECHNOLOGIES PVT. LTD., S1, WIPRO ELECTRONIC CITY, SPECIAL ECONOMIC ZONE, DODDATHOGUR VILLAGE, BEGUR HOBLI, ELECTRONIC CITY, BANGALORE - 560 100. REPRESENTED HEREIN BY ITS DIRECTOR PAN NO. AAACC4971D. ...PETITIONER (BY SMT. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX, TRANSFER PRICING, DC/ACIT TP 1(1)(2) BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE - 560 095. - 3 - HC-KAR NC: 2026:KHC:14907 WP No. 27816 of 2024 C/W WP No. 27815 of 2024 2. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(2)(1) BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE - 560 095. ...RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ORDER DATED 19.09.2024 (ANNEXURE-'F') BEARING DIN ITBA/COM/F/17/2024-25/1068847866(1) PASSED BY THE 1ST RESPONDENT FOR THE ASSESSMENT YEAR 2018-19 AND ETC. THESE PETITIONS COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S SUNIL DUTT YADAV ORAL ORDER Learned counsel for the petitioner has filed a memo for withdrawal, which reads as under: "MEMO FOR WITHDRAWAL The Advocate for the Petitioner most humbly submits as under: The above petition is filed questioning the legality and validity of the order dated 19.09.2024 passed by the 1st Respondent under Section 154 of - 4 - HC-KAR NC: 2026:KHC:14907 WP No. 27816 of 2024 C/W WP No. 27815 of 2024 the Income-tax Act, 1961, recomputing the outstanding dues receivable from the Petitioner's Associated Enterprises ("AEs") for the assessment year 2017-18. During the pendency of the above petition, the Petitioner has settled the dispute involved in the present petition by invoking the provisions of Mutual Agreement Procedure ("MAP") under the Double Taxation Avoidance Agreement between India and United States of America. Pursuant to the above, an order dated 27.01.2026 was passed in terms of Rule 44G of the Income-tax Rules, 1962. In view of the above, the present petition has become infructuous and thus the Petitioner craves leave of the Hon'ble Court to withdraw the above petition. Wherefore, it is most humbly prayed that this Court be pleased to dispose of the above petition as "withdrawn" in the interests of justice and equity." 2. Taking note of the contents of the memo, the petition is disposed of as not calling for adjudication. Sd/- (S SUNIL DUTT YADAV) JUDGE SHS