Ita/97/2017 Of Intel Corporation v. The Deputy Director Of Income - Tax

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28[tn]DAY OF SEPTEMBER 2020. PRESENT THE HON’BLE MR. JUSTICE ALOK ARADHE AND| THE HON’BLE MR. JUSTICE M.I. ARUN. LT.A. NO.97 OF 2017 BEI|WEEN INTEL CORPORATIONA COMPANY [INCORPORATED UNDERTHE LAWS OF THE UNITED STATES OF AMERICAC/O. INTEL TECHNOLOGY INDIA P. LTDSRR2, NO.23-56P|DEVARABEESANAHALLIOUTER RING ROAD|BANGALORE SOUTH TALUKBANGALORE-5600 37REP. HEREIN BY ITS AUTHORISED SIGNATORY.MS, SUMITA THOMAS. ALSO AT:$ FLOOR, EMBASSY PARAGON BUILDING.SITE NO.6/2 & 6/3, THOBARAHALLI VILLAGENEAR KUNDALAHALLI GATEITPL ROAD, BANGALORE-3/7. .., APPELLANT— (BY SMT. TANMAYI RAJKUMAR, ADV., FORSRI. T. SURYANARAYANA, ADV.,) AND" 1.THE DEPUTY DIRECTOR OF INCOME-TAX. (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALOREBMTC BUILDING, KORAMANGALA 6 BLOCKBANGALORE-560095.BMTC BUILDING, KORAMANGALA 6 BLOCKBANGALORE-560095. 2).THE DIRECTOR OF INCOME-TAX (INTERNATIONAL TAXATION), BANGALORE| BMTC BUILDING, KORAMANGALA 6 BLOCK BANGALORE-560095. ... RESPONDENTS. (BY SRI. K.V. ARAVIND, ADV.,) THIS kI§I.T.A. IS FILED UNDER SECTION 2600-AIL.T.ACT, 1961, ARISING OUT OF ORDER DATED 30-09-2016PASSED|IN|IT(TP)ANO.1468/BANG/ 2013,FORTHE|ASSESSMENT YEAR 2008-09, PRAYING TO: I. FORMULATE THE SUBSTANTIAL QUESTIONS OF LAW|STATED THEREIN.» I]. ALLOW THE APPEAL AND SET ASIDE THE ORDER)PRONOUNCED ON 30-09-2016 BY THE TRIBUNAL IN IT(TP)A.NO.1486/BANG/2013—(ANNEXURE-D), TO)THE|EXTENT|QUESTIONED HEREIN. III. PASS SUCH OTHER OR FURTHER ORDERS AS THIS!HON BLE COURT DEEMS FIT TO PASS ON THE FACTS AND IN|THE CIRCUMSTANCES OF THE CASE AND IN THE INTERESTS|OF JUSTICE AND EQUITY. THIS I.7T.A. COMING ON FOR ORDERS, THIS DAY,ALOK ARADHE J.,DELIVERED THE FOLLOWING: JUDGMENT Smt.Tanmayee Rajkumar, learned counsel! forMr.T.Suryanarayana, learned counsel for the assessee. Mr.K.V.Aravind, learned counsel accepts notice on|behalf of the respondent. ?. Learned counsel for the assessee has filed a.memo seeking leave of this Court to withdraw theappeal. The aforesaid memo is taken on record. 3. For the reasons assigned in the memo, the)appeal is dismissed as withdrawn. RV| Sd/-JUDGE Sd/-"JUDGE