- 1 - HC-KAR NC: 2025:KHC:45059 WP No. 9693 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 6TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 9693 OF 2024 (T-IT) BETWEEN: ADITHYA BOGGARAM SETTY (S/O B R VISWANATHA SETTY AGED ABOUT 41 YEARS) IA 701 WING A, 7TH FLOOR, ASCENT TOWER PENINSULA HEIGHTS, 46/1, 17TH MAIN, JP NAGAR 2ND PHASE, BENGALURU – 560 078. …PETITIONER (BY SRI. TATA KRISHNA, ADVOCATE) AND: 1. CENTRALIZED PROCESSING CENTRE (REPRESENTED BY DEPUTY DIRECTOR OF INCOME TAX CPC, BENGALURU) INCOME TAX DEPARTMENT, BENGALURU – 560 500. 2. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7(1)(1), 5TH FLOOR, BMTC BUILDING, 80FT ROAD, 6TH BLOCK, KORAMANGALA, BENGALURU – 560 095. …RESPONDENTS (BY SRI. ARAVIND V. CHAVAN, ADVOCATE FOR R1; SRI. E.I. SANMATHI, ADVOCATE FOR R2) THIS W.P. IS FILED UNDER ARTICLE 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO DIRECT THE RESPONDENTS TO GRANT REFUND OF THE SUM OF RS. 1,99,60,460/- FOR THE ASSESSMENT YEAR 2020-21 VIDE ORDER DATED 29.06.2021, COPY OF ORDER ENCLOSED S ANENXURE-A AND ETC., Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:45059 WP No. 9693 of 2024 THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks for the following reliefs:- “(A) Issue as far as the Petitioner is concerned and appropriate writ or order in the nature of Mandamus or otherwise, directing the Respondents to grant refund of the sum of Rs.1,99,60,460/- for the Assessment Year 2020-21 vide order dated 29.06.2021, copy of order enclosed as Annexure-A. (B) Issue as far as the Petitioner is concerned an appropriate writ or order in the nature of Mandamus or otherwise directing the Respondents to grant interest on refund as stipulated under Section 244A(1)(a)(i) of the Assessment Year 2020-21; (C) Grant such other reliefs as this Honourable High Court may think fit including the costs of this writ petition.” 2. Heard learned counsel for the petitioner and learned counsel for respondent Nos.1 and 2 and perused the material on record. - 3 - HC-KAR NC: 2025:KHC:45059 WP No. 9693 of 2024 3. Learned counsel for the petitioner submits that insofar as the refund claimed by the petitioner at Prayer (A) is concerned, the same was sanctioned and granted to the petitioner on 18.04.2024, after the present petition was preferred by the petitioner before this Court. It is submitted that insofar as Prayer (B) relating to balance interest receivable by the petitioner under Section 244A(1)(a)(i), of the Income Tax Act and the compensatory interest thereon is concerned, the petitioner would be entitled to a sum of Rs.50,49,997/- as hereunder: STATEMENT OF BALANCE INTEREST RECEIVABLE U/S 244A(1)(a)(i) OF THE IT ACT AND COMPENSATORY INTEREST THEREON SL. NO. PARTICULARS Working Rs. A Net Tax Liability as per Intimation u/s 143(1) 7,51,209 B Advance tax/ TDS paid as per Intimation u/s 143(1) 2,07,11,665 C REFUND RECEIVABLE AS PER INTIMATION U/S 143(1) C = B – A 1,99,60,456 D Interest Commencing from 01-Apr-20 E Date of Refund Received 18-Apr-24 F DIFFERENCE IN MONTHS F = E – D 49 (4 yrs 18 days) - 4 - HC-KAR NC: 2025:KHC:45059 WP No. 9693 of 2024 G Interest u/s 244A(1)(a)(i) – Interest of 0.5% for every month or part of a month comprised in the period from the 01.04.2020 till the date on which the refund is granted, in the instant case received on 18.04.2024 G = C X F X 0.5% 48,90,312 H TOTAL REFUND AND INTEREST RECEIVABLE H = C+G 2,48,50,768 I Less: Amount received on 18.04.2024 2,02,59,862 J BALANCE RECEIVABLE J = H-I 45,90,906 K Compensatory Interest @ 6% per annum from April 2024 to November 2025 (20 Months) K 4,59,091 L TOTAL INTEREST RECEIVABLE L = J+K 50,49,997 4. It is submitted that having regard to the fact that the refund had already been determined to be granted in favour of the petitioner as long back as on 31.03.2021 and that the same was undisputedly paid by the respondents to the petitioner on 18.04.2024 after filing the present petition, the petitioner would be entitled to interest and compensatory interest in terms of Section 244A(1)(a)(i) of the IT Act, which may be directed to be paid by the respondents to the petitioner. 5. 5. Per contra, learned counsel for the respondents submits that the respondent No.2 would verify the claim of the petitioner for grant of interest as stated supra and grant interest in - 5 - HC-KAR NC: 2025:KHC:45059 WP No. 9693 of 2024 accordance with law and in terms of the provisions contained in Section 244A(1)(a)(i) of the IT Act within a stipulated time frame. 6. In view of the aforesaid facts and circumstances and in the light of the undisputed facts and the respondents already granted refund in a sum of Rs.1,00,000/- as sought for by the petitioner in prayer number (A) on 18.04.2024 during the pendency of the present petition, I deem it just and appropriate to dispose of this petition by issuing certain directions to the respondents. 7. In the result, I pass the following: ORDER (i) The petition is hereby disposed of. (ii) The prayer (A) sought for by the petitioner does not survive any longer in view of the refund already having been paid by the respondents to the petitioner on 18.04.2024 during the pendency of the present petition. (iii) Insofar as prayer (B) is concerned, the respondent No.2 shall consider the claim of the petitioner as sought for in the statement of calculation as mentioned supra and take appropriate - 6 - HC-KAR NC: 2025:KHC:45059 WP No. 9693 of 2024 steps to grant refund of interest in favour of the petitioner in accordance with law and in terms of Section 244A(1)(a)(i) of the Income Tax Act within a period of 2 months from the date of receipt of a copy of this order. Sd/- (S.R.KRISHNA KUMAR) JUDGE MDS List No.: 2 Sl No.: 31