The Commissioner of Income Tax , v. M/S Altair Engineering Inc.
Case brief
What is this about?
Karnataka High Court, Bengaluru | ITA No. 60 of 2024 | Commissioner of Income Tax, International Taxation & ITO International Taxation Circle 1(1) v. M/s Altair Engineering Inc. | royalty liability on receipts for sale of software | assessment year 2020-21 | appeal under Section 260-A, Income Tax Act 1961 | impugned: ITAT Bengaluru order in IT(IT)A No. 642/Bang/2023 dated 30/10/2023 | DRP confirmation of ITO order | reliance on Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT, [2021] 432 ITR 471 (SC) | related Revenue appeals ITA Nos. 708/2023 (AY 2019-20) and 135/2024 (AY 2021-22) | coordinate bench parity | Bench: B M Shyam Prasad, J. (author) and T.M. Nadaf, J. | decided 15 October 2025 | appeal dismissed.
What did the court decide?
The appeal stands dismissed because, with the coordinate bench having held that the Revenue has not demonstrated any difference in facts or law relevant to the other assessment years (where similar appeals were disposed of in view of the Apex Court decision in Engineering Analysis Centre of Excellence), that observation admittedly applies to the present assessment year 2020-21.