- 1 - HC-KAR CNR: KAHC010136302024 NC: 2026:KHC:41462-DB ITA No. 106 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 6TH DAY OF AUGUST, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE DR. JUSTICE K.MANMADHA RAO INCOME TAX APPEAL NO. 106 OF 2024 BETWEEN: 1. PR. COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) KORAMANGALA, BANGALORE. 2. THE ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAX, INTERNATIONAL TAXATION, CIRCLE 1(2), KORMANGALA, BANGALORE. …APPELLANTS (BY SRI. E I SANMATHI & SRI NIRMAL MATHEW, ADV.) AND: M/S. SYNAMEDIA LIMITED (FORMERLY KNOWN AS NDS LIMITED) BLOCK, NO.9A AND 9B PRINTECH PARK, SURVEY NO.51-64/4, SARJAPUR OUTER RING ROAD, BELLANDUR VILLAGE, BENGALURU-560103 PAN. AABCN2524L. …RESPONDENT (BY MS. MANASA ANANTHAN, ADV. FOR MS. TANMAYEE RAJKUMAR, ADV.) Digitally signed by NANJUNDACHARI Location: High Court of Karnataka - 2 - HC-KAR CNR: KAHC010136302024 NC: 2026:KHC:41462-DB ITA No. 106 of 2024 THIS APPEAL IS FILED UNDER SEC.260-A OF INCOME TAX ACT 1961, ARISING OUT OF ORDER DATED 12/11/2021 PASSED IN IT(IT)A NO.505/BANG/2017 FOR THE ASSESSMENT YEAR 2013-14, PRAYING TO 1). DECIDE THE FOREGOING QUESTION OF LAW AND/OR SUCH OTHER QUESTIONS OF LAW AS MAY BE FORMULATED BY THE COURT AS DEEMED FIT AND SET ASIDE THE APPELLATE ORDER DATED 12/11/2021 PASSED BY THE INCOME TAX APPELLATE TRIBUNAL, ‘B’ BENCH, BANGALORE, AS SOUGHT FOR, IN THE RESPONDENT- ASSESSEE’S CASE, IN APPEAL PROCEEDINGS IN IT(IT)A NO.505/BANG/2017 FOR A.Y 2013-14 (ANNEXURE-A) AND GRANT SUCH OTHER RELIEF AS DEEMED FIT, IN THE INTEREST OF JUSTICE. THIS APPEAL, COMING ON FOR ORDERS, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.G.PANDIT AND HON'BLE DR. JUSTICE K.MANMADHA RAO ORAL JUDGMENT (PER: HON'BLE MR. JUSTICE S.G.PANDIT) Heard learned counsel Sri.E.I.Sanmathi for appellants/Revenue and learned counsel Ms. Manasa Ananthan for Ms. Tanmayee Rajkumar for respondent/assessee. Perused the appeal papers. 2. The above appeal is filed under Section 260A of the Income Tax Act, 1961 questioning common order - 3 - HC-KAR CNR: KAHC010136302024 NC: 2026:KHC:41462-DB ITA No. 106 of 2024 dated 12.11.2021 in IT(IT)A.No.505/Bang/2017 for the assessment year 2013-14 passed by the Income Tax Appellate Tribunal, ‘B’ Bench, Bengaluru (for short, ‘the Tribunal’). 3. During the course of hearing, it is brought to our notice that the common order passed by the Tribunal was the subject matter of ITA.No.109/2024 wherein the common order passed in IT(IT)A.No.505/Bang/2017 for the assessment year 2012-13 was under challenge and the appeal was dismissed by following the judgment of the Hon'ble Apex Court in the case of ENGINEERING ANALYSIS CENTRE OF EXCELLENCE PRIVATE LIMITED VS. COMMISSIONER OF INCOME-TAX AND ANOTHER (2021) 432 ITR 471. 4. Since the common order passed by the Tribunal is already upheld, we dismiss the present appeal, following the order passed in ITA.No.109/2024 dated 19.08.2025 - 4 - HC-KAR CNR: KAHC010136302024 NC: 2026:KHC:41462-DB ITA No. 106 of 2024 between the same parties for the assessment year 2012-13. 5. In view of dismissal of the appeal, I.A.No.1/2026 stands disposed of. Sd/- (S.G.PANDIT) JUDGE Sd/- (DR.K.MANMADHA RAO) JUDGE NC CT:bms List No.: 1 Sl No.: 9