Karnataka High Court
The Pr. Commissioner vs M/S Google India Pvt Ltd on 8 October, 2025
Author: B M Shyam Prasad
Bench: B M Shyam Prasad
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NC: 2025:KHC:39640-DB
ITA No. 136 of 2024
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 8TH DAY OF OCTOBER, 2025
PRESENT
THE HON'BLE MR. JUSTICE B M SHYAM PRASAD
AND
THE HON'BLE MR. JUSTICE T.M.NADAF
INCOME TAX APPEAL NO. 136 OF 2024
BETWEEN:
1. THE PR. COMMISSIONER
OF INCOME TAX -3
BANGALORE
2. THE JOINT COMMISSIONER
OF INCOME TAX
SPECIAL RANGE-3
Digitally signed BENGALURU
by
MADHUSHREE
H
Location: High ...APPELLANTS
Court of
Karnataka (BY SRI. E.I. SANMATHI, ADVOCATE)
AND:
M/S GOOGLE INDIA PVT LTD.,
NO.3, RMZ INFINITY TOWER-E,
4th FLOOR,
OLD MADRAS ROAD,
BANGALROE 560016
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NC: 2025:KHC:39640-DB
ITA No. 136 of 2024
HC-KAR
PAN AACCG5027D
...RESPONDENT
(BY SRI. ANMOL ANAND, ADVOCATE FOR
SRI. MRINAL SHANKAR, ADVOCATE)
THIS ITA / Income Tax Appeal IS FILED
UNDER SEC.260-A OF INCOME TAX ACT 1961,
ARISING OUT OF ORDER DATED 31-10-2023
PASSED IN M.P.NO.201/BANG/2023 FOR A.Y. 2015-
16 (ANNEUXRE-A) FOR THE ASSESSMENT YEAR
2015-16. PRAYING THAT THIS
HONBLE COURT BE PLEASED
A)DECIDE THE FOREGOING QUESTION OF LAW
AND / OR SUCH OTHER QUESTIONS OF LAW AS
MAYBE FORMULATED BY THE HONBLE COURT AS
DEEMED FIT AND SET ASIDE THE APPELLATE
ORDER DATED 31.10.2023 PASSED BY THE
INCOME TAX APPELLATE TRIBUNAL, C BENCH,
BANGALORE, AS SOUGHT FOR, IN THE
RESPONDENT-ASSESSEES CASE, IN APPEAL
PROCEEDINGS IN M.P.NO.,201/BANG/20213 FOR
A.Y.2015-16(ANNEXURE-A)
THIS APPEAL, COMING ON FOR ADMISSION,
THIS DAY, JUDGMENT WAS DELIVERED THEREIN
AS UNDER:
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NC: 2025:KHC:39640-DB
ITA No. 136 of 2024
HC-KAR
CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD
and
HON'BLE MR. JUSTICE T.M.NADAF
ORAL JUDGMENT
(PER: HON'BLE MR. JUSTICE B M SHYAM PRASAD) The Revenue is in appeal as against the order dated 31.10.2023 in M.P.No.201/Bang/2023 (in IT(TP)A No.2301/Bang/2019) on the file of the Income Tax Appellate Tribunal "C" Bench, Bengaluru [for short, 'the Tribunal']. This order is relevant to the Assessment Year 2015-16 and is based on the Tribunal's orders in the assessee's sister concern which are relevant to the Assessment Years 2010-11 and 2012-13.
The Tribunal's order relevant to these years in IT(IT)A No.167/Bang/2021 and IT(IT)A No.688/Bang/2022 are called in question before this Court in ITA No.653/2023 c/w ITA No.657/2023, and this Court has disposed of these appeals observing that the proposed substantial questions of -4- NC: 2025:KHC:39640-DB ITA No. 136 of 2024 HC-KAR law are answered by a Co-ordinate Bench of this Court in the Deputy Commissioner of Income Tax (International Taxation) Vs. Flipkart Internet (P) Ltd. reported in (2025) 171 Taxmann.com 693 (Karnataka).
Mr. E.I. Sanmathi, the learned Senior standing counsel for the Revenue, and Mr. Anmol Anand, the learned counsel who appears for the respondent, are heard. The appeal stands disposed of in the light of the afore.
Sd/-
(B M SHYAM PRASAD) JUDGE Sd/-
(T.M.NADAF) JUDGE RB