COMMISSIONER OF INCOME TAX Vs. TRILOGY E

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, 'A' Bench, Bangalore, dated 30.06.2011 passed in ITA No.1201/Bang/2010 (Trilogy E-Business Software India Pvt. Ltd., v. The Dy.Commissioner of Income Tax) for A.Y.2006-07.

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

(3.) The learned counsel appearing for the Appellants - Revenue Mr.Jeevan J. Neeralgi submitted that in so far as the first substantial question of law is concerned, the same is covered by the decision of the Hon'ble Apex 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:-