- 1 - HC-KAR NC: 2025:KHC:31509 WP No. 13017 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 14TH DAY OF AUGUST, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 13017 OF 2025 (T-IT) BETWEEN: M/S. MICROLAND LIMITED A PUBLIC LIMITED COMPANY NO. 1B, RMZ ECOSPACE BUSINESS PARK OUTER RING ROAD, BELANDUR BENGALURU – 5260 103 REPRESENTED BY ITS DIRECTOR-FINANCE MR. BENJAMIN JOHN ABRAHAM EMAIL ID: benjamin.abraham@micoland.com MOB NO. 9845608293. …PETITIONER (BY SRI K.R.PRADEEP, ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(1)(1), BENGALURU BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, KORAMANGALA BENGALURU – 560 095. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU – 2 BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, KORAMANGALA Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:31509 WP No. 13017 of 2025 BENGALURU – 560 095. 3. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, BENGALURU KARNATAKA AND GOA CENTRAL REVENUE BUILDING 1, QUEENS ROAD, SHIVAJINAGAR BENGALURU – 560 001. …RESPONDENTS (BY SRI SUSHAL TIWARI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO DIRECT THE 1ST RESPONDENT TO PASS THE RECTIFICATION ORDER GIVING CREDIT TO PREPAID TAXES INCLUDING TAXES PAID OUTSIDE INDIA BY THE PETITIONER AND ISSUE THE RESULTANT REFUND AS PER RETURN OF INCOME FILED ON 30.03.2016 AS PER ANNEXURE – A ALONG WITH INTEREST UNDER SECTION 244A OF THE ACT FOR THE ASSESSMENT YEAR 2014-15 WITHIN REASONABLE TIME AS MAY BE PRESCRIBED BY THIS HON’BLE COURT. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:31509 WP No. 13017 of 2025 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner – assessee is before this Court seeking a direction to respondent No.1 to refund the tax deducted at source including the taxes paid outside the country, for the assessment years 2014-15 and 2015-16. 2. Heard Sri K.R.Pradeep, learned counsel for petitioner and Sri Sushal Tiwari, learned counsel for respondents. 3. The petitioner files returns of income for the assessment years 2014-15 and 2015-16 on 29.11.2014 and 30.09.2015, respectively. Coming to know about the original returns of income as aforesaid did not reflect the entire income taxes paid by the petitioner, which include the income taxes paid in the country and also outside the country, files revised returns of income along with computation of income on 30.03.2016 and 31.03.2016, respectively. 4. The revised returns so filed by the petitioner were subjected to scrutiny and the petitioner furnished all the particulars and details in the proceedings. Respondent No.1 after due consideration of the records submitted by the - 4 - HC-KAR NC: 2025:KHC:31509 WP No. 13017 of 2025 petitioner, assessment orders are passed accepting the revised returns filed by the petitioner and also indicating the amount of refund for the assessment years 2014-15 and 2015-16 but erred in giving credit to the prepaid taxes paid outside India for the assessment year 2014-15 and also indicating ‘NIL’ refund for the assessment year 2015-16. 5. The grievance of the petitioner is that, though he has submitted plethora of rectification applications for the aforesaid assessment years and also reminders, the respondents – revenue has not considered the same. The petitioner has also complained on the Income Tax Portal – CPGRAM and the same is turned down by the respondents – revenue on the score that the earlier orders passed against the petitioner are not challenged by preferring an appeal. It is these orders that has driven the petitioner to this Court in the subject petition. 6. Learned counsel for respondents – revenue would on the issue submit that the rectification applications filed by the petitioner for the aforesaid assessment years would be considered, if two weeks time is granted by this Court. - 5 - HC-KAR NC: 2025:KHC:31509 WP No. 13017 of 2025 7. In the light of the aforesaid submissions, the respondents – revenue is directed to consider the rectification applications filed by the petitioner and pass necessary orders in accordance with law, within two weeks from the date of receipt of a copy of the order. 8. With the aforesaid observation, writ petition stands allowed. Ordered accordingly. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 19 CT:SS