Tricentis Gmbh,Austria vs The Deputy Commissioner Of Income-Tax, ... on 6 November, 2024
5. Having considered rival submissions, we find, the issue is
squarely covered against the assessee by the decision of the
Hon'ble Karnataka High Court in case of Adarsh Developers Vs.
DCIT (supra). No other contrary decision was brought to our
notice by either of the parties. Since, above mentioned decision is
the only decision of High Court available before us, respectfully
following the ratio laid down therein, we hold that the impugned
assessment orders are valid. Accordingly, ground no. 2 in both
the appeals are dismissed.