THE PR. COMMISSIONER OF INCOME Vs. M/S. GT NEXUS SOFTWARE PVT. LTD., THE SIRIUS, 69/3, MILLERS ROAD, BENGALURU

JUDGEMENT

(1.) The Appellants-Revenue have filed this appeal under section 260A of the Income Tax Act, 1961, raising purportedly certain substantial questions of law arising from the order of the ITAT, Bangalore Bench 'B', dated 18.04.2017 passed in IT(TP)A No.409/Bang/2016 for the A.Y.2011-12.

(2.) The proposed substantial questions of law framed in the Memorandum of appeal by the Appellants-Revenue are quoted below for ready reference:-

(3.) Regarding substantial question of law No.2:- The controversy is no longer res integra and is covered by the decision of the Division Bench of this Court in the case of M/s. Tata Elxsi Ltd., v. Asst.Commissioner of Income Tax, decided on 20.10.2015 since reported in (2015) 127 DTR 0327 (Kar), which has been affirmed by 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:-