THE PR. COMMISSIONER OF INCOME TAX KORAMANGALA Vs. M/S. CYPRESS SEMICONDUCTORS TECHNOLOGY INDIA PVT. LTD.

JUDGEMENT

(1.) This Appeal is filed by the Revenue purportedly raising substantial questions of law arising from the Order of the Income Tax Appellate Tribunal, 'A' Bench, Bangalore, in C.O.No.166/Bang/2015 dated 04.11.2016 relating to the Assessment Year 2005-06.

(2.) The substantial questions of law framed by the Revenue in the Memorandum of Appeal are as under:

(3.) The issue is covered by the decision of the Hon'ble Supreme Court in the case of Commissioner of Income-tax, Central - III v. HCL Technologies Ltd., [2018] 93 Taxmann.com 33(SC) . The relevant portion of the judgment of the Hon'ble Supreme Court in the case of HCL Technologies Ltd. (supra), is quoted below for ready reference:-