- 1 - HC-KAR NC: 2025:KHC:50045 WP No. 13081 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 1ST DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO.13081 OF 2025 (T-IT) BETWEEN: PEOPLE EDUCATION TRUST 01, PET TRUST OFFICE BUILDING, PES ENGINEERING COLLEGE ROAD, MANDYA CITY, MANDYA – 571 401 REPRESENTED BY ITS SECRETARY, SRI.SOMANAHALLI LINGAIAH SHIVAPRASAD, AGED ABOUT 80 YEARS, S/O.SOMANAHALLI CHIKKEGOWDA LINGAIAH, NATURE OF BUSINESS EDUCATIONAL INSTITUTION. …PETITIONER (BY SRI. S PARTHASARATHI, ADVOCATE) AND: THE COMMISSIONER OF INCOME TAX (EXEMPTIONS), UNITY BUILDING ANNEXE, MISSION ROAD, BENGALURU – 560 027. …RESPONDENT (BY SRI. ARAVIND V.CHAVAN, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE IMPUGNED ORDER BEARING NO.ITBA/EXM/F/EXM45/2024-25/1075348211(1) DTD. 31.03.2025 PASSED BY THE RESPONDENT (ANNX-D) AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:50045 WP No. 13081 of 2025 CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks the following reliefs: “a) Issue a Writ of Certiorari or a direction in the nature of Writ of Certiorari quashing the impugned order bearing No.ITBA/EXM/F/EXM45/2024-25/1075348211(1) dated 31.03.2025 passed by the Respondent (Annexure-‘D’); b) Issue a Writ of mandamus directing the Respondent to continue the registration of the Trust under Section 12A of the Act. c) Issue a Writ of Prohibition or a direction in the nature of prohibition restraining the Respondent from initiating any subsequent proceeding to pass Assessment Order and raise impugned demand for the purpose of recovery. d) Pass such other order, direction or writ as this Hon’ble Court deems fit, and e) Direct the Respondents to award the costs of this Writ Petition.” 2. Heard learned counsel for the petitioner and learned counsel for the respondent and perused the material on record. 3. A perusal of the material on record will indicate that the petitioner having filed an application seeking continuation of - 3 - HC-KAR NC: 2025:KHC:50045 WP No. 13081 of 2025 Registration in Form No.10AB, the case was assigned to the jurisdictional Assessing Officer for verification, in pursuance of which, the Assessing Officer proceeded to submit a report to the CIT (Exemptions), who proceeded to pass the impugned order by placing reliance upon the Investigation Report and other documents, without providing sufficient or reasonable opportunity to the petitioner and not furnishing / providing the Investigation Report thereby violating the principles of natural justice. 4. Under these circumstances, on this short ground alone for violation of principles of natural justice on the part of the respondent in not providing sufficient or reasonable opportunity to the petitioner, I deem it just and appropriate to set aside the impugned order and remit the matter back to the respondent for reconsideration afresh in accordance with law. 5. In the result, I pass the following: ORDER (i) The petition is hereby allowed. (ii) The impugned order at Annexure – D dated 31.03.2025 passed by the respondent is hereby set aside. - 4 - HC-KAR NC: 2025:KHC:50045 WP No. 13081 of 2025 (iii) The matter is remitted back to the respondent for reconsideration of the matter afresh. (iv) The petitioner is directed to appear before the respondent on 12.01.2026 without awaiting further notice from the respondent. (v) Liberty is reserved in favour of the petitioner to submit replies, documents etc., which shall be considered by the respondent, who shall provide sufficient and reasonable opportunity to the petitioner and hear it and proceed further in accordance with law. (vi) In the event, the petitioner does not appear before the respondent on 12.01.2026 as stated supra, present order shall stand automatically recalled without further orders. Sd/- (S.R.KRISHNA KUMAR) JUDGE SV List No.: 2 Sl No.: 36