- 1 - HC-KAR NC: 2026:KHC:7234-DB RP No. 151 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 6TH DAY OF FEBRUARY, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE C.M. POONACHA REVIEW PETITION NO. 151 OF 2025 BETWEEN: 1. THE COMMISSIONER OF INCOME TAX CIT(A), 4TH FLOOR, BMTC BUILDING, 60 FEET ROAD, KORMANGALA, BANGALORE-560085. 2. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION CIRCLE 1(2), 4TH FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU-560095. …PETITIONERS (BY SRI. SANMATHI E. I., ADV.) AND: M/S. CGI INFORMATION SYSTEMS AND MANAGEMENT CONSULTANTS PVT. LTD., NO.95/1 AND 95/2. E CITY TOWER-2, ELECTRONIC CITY, PHASE-21, WEST BENGALURU-560100 PAN AAAC1199AC …RESPONDENT (BY SMT. TANMAYEE RAJKUMAR, ADV.) THIS REVIEW PETITION FILED UNDER SECTION ORDER 47 RULE 1 AND 2 OF CPC, PRAYING TO A) REVIEW JUDGMENT DATED 23.09.2024 PASSED IN ITA NO.97/2022 AND B) TO PASS SUITABLE ORDERS THAT THIS COURT DEEMS FIT TO BE GRANTED IN THE Digitally signed by NANJUNDACHARI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:7234-DB RP No. 151 of 2025 FACTS AND CIRCUMSTANCES OF THE CASE IN THE INTEREST OF JUSTICE AND EQUITY. 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) The above review petition is filed under Order 47 Rules 1 and 2 of CPC, 1908 praying to review the order dated 23.09.2024 in ITA No.97/2022 dismissing the appeal noting that tax effect in that appeal is less than Rs.2 Crores. 2. Heard learned counsel Sri. E I Sanmathi for petitioner-Revenue and Ms.Tanmayee Rajkumar, learned counsel for respondent – Assessee. 3. Learned counsel for the Revenue, Mr. Sanmathi would submit that the case of the respondent would fall under exception clause 3.1(i) and (ii) of CBDT Circular - 3 - HC-KAR NC: 2026:KHC:7234-DB RP No. 151 of 2025 No.5/2024 dated 15.03.2024. Hence, he submits that the appeal could not have been disposed of as not maintainable. Learned counsel for the petitioner however brings to the notice of this court the subsequent judgment dated 12.08.2025 passed in ITA No.723/2023 wherein the identical or similar contention of the appellant is rejected. 4. Taking note of the fact that monetary value that was involved in the appeal was within Rs.2 Crores in ITA No.97/2022 and in view of the above said judgment in ITA No.723/2023, the present review petition also stands dismissed. Sd/- (S.G.PANDIT) JUDGE Sd/- (C.M. POONACHA) JUDGE BSV CT:bms List No.: 1 Sl No.: 11