By Sri v. Chandrasekhar, Advocate

Digitally signedby SHAKAMBARILocation: HIGHCOURT OFKARNATAKA NC: 2024:KHC:25833-DB WA No. 320 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8 DAY OF JULY, 2024 PRESENT THE HON'BLE MR JUSTICE KRISHNA S DIXIT AND THE HON'BLE MR JUSTICE RAMACHANDRA D. HUDDAR -WRIT APPEAL NO. 320 OF 2024 (TIT) BETWEEN: THE DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(1), BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU 560 095 …APPELLANT (BY SRI. Y.V. RAVIRAJ, SENIOR STANDING COUNSEL) AND: M/S. AD2PRO MEDIA SOLUTIONS INC., USA REP. BY ITS AUTHORIZED SIGNATORY SRI. VENKATESAPERUAMAL GOPALAKISHNAN, SON OF LATE SRI. VENKATESAPERUMAL AGED ABOUT 63 YEARS, NO. 23371, MULHOLLAND DR. NO. 132, WOODLAND HILLS, CA 91364 USA …RESPONDENT (BY SRI. V. CHANDRASEKHAR, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT PRAYING TO SET ASIDE THE ORDER PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.4409/2021 DATED 13/04/2023. THIS APPEAL, COMING ON FOR ORDERS, THIS DAY, KRISHNA S DIXIT J., DELIVERED THE FOLLOWING: JUDGMENT The challenge is to the order of the learned Single Judge dated 13.04.2023 passed in Writ Petition No.4233/2021(T-IT), whereby a batch of petitions having been favoured, the Assessees therein have been granted relief. 2. On perusal of the paper book, we notice that the learned Single Judge has followed the decision of a Co-ordinate Bench of this Court in ITA No.232/2020 and connected matters. We do not find any error in the learned Single Judge's order, applying the ratio of the said decision to the subject petition and granting the relief to the Assessees. - 3 - In view of the above, the appeal being unworthy of merits, is liable to be and accordingly rejected, costs having been made easy. Sd/- JUDGE YN List No.: 1 Sl No.: 9 Sd/- JUDGE