- 1 - HC-KAR NC: 2025:KHC:47207 WP No. 9876 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 13TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 9876 OF 2025 (T-IT) BETWEEN: MPHASIS LIMITED WTC 3, BAGMANE WORLD TECHNOLOGY CENTRE MAHADEVAPURA S.O., BENGALURU NORTH, BENGALURU – 560 037. A PUBLIC LISTED LIMITED COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 AND REPRESENTED BY ITS AUTHORIZED SIGNATORY, MR ARIJIT GANGULY S/O. AMITAVA GANGULY AGED ABOUT 53 YEARS OCC: SR VP AND GROUP HEAD- TAXATION RESIDING AT BAGMANE TECHNOLOGY PARK, LAUREL BUILDING, CV RAMAN NAGAR, BENGALURU - 560 003. …PETITIONER (BY SRI. K R VASUDEVAN, ADVOCATE) AND: 1. ASSESSMENT UNIT /INCOME TAX OFFICER INCOME TAX DEPARTMENT MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI 110001. 2. ASSISTANT COMMISSIONER OF INCOME-TAX CIRCLE 4(1)(1), BMTC BUILDING, 80 FT. ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095. Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:47207 WP No. 9876 of 2025 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX RANGE 4, BENGALURU BMTC BUILDING, 80 FT. ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095. …RESPONDENTS (BY SRI. E.I.SANMATHI, ADVOCATE) THIS W.P IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO-ISSUE A WRIT OF CERTIORARI OR ANY OTHER WRIT AS THE HONBLE HIGH COURT MAY DEEM FIT AND QUASH THE ANNEXURE – E –IMPUGNED ASSESSMENT ORDER DATED 07.03.2025 PASSED BY THE RESPONDENT NO.1 UNDER SECTION 143(3) READ WITH SECTION 144B OF THE ACT FOR THE AY 2022-23 IN DIN & ORDER NO. ITBA/AST/S/143(3)/2024-25/1074188533 AND ETC. 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 the following reliefs: “ (i) Issue a writ of certiorari or other writ as the Hon'ble High Court may deem fit and quash the following: ANNEXURE 'E' : Impugned assessment order dated 07.03.2025 passed by the Respondent No.1 under section 143(3) read with section 144B of the Act for the AY 2022-23 in DIN & Order No. ITBA/AST/S/143(3)/2024-25/1074188533(1) ANNEXURE 'E1' : Impugned computation sheet dated: 07.03.2025 passed by the Respondent No.1 under section 143(3) of the Act for the AY 2022-23 in DIN & Document No. ITBA/AST/S/622/2024- 25/1074188881(1) - 3 - HC-KAR NC: 2025:KHC:47207 WP No. 9876 of 2025 ANNEXURE 'E2' : Impugned demand notice dated 07.03.2025 issued by the Respondent No.1 under section 156 of the IT Act for the AY 2022-23 in DIN & Notice No. ITBA/AST/S/156/2024- 25/1074188699(1) (ii) issue any other writ, order or direction to which Petitioner is found entitled to in the present fact circumstances.” 2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 3. A perusal of the material on record will indicate that pursuant to the Show Cause Notice dated 17.02.2025 issued by respondent No.1, petitioner submitted a detailed reply dated 21.02.2025. Thereafter, personal hearing was scheduled to be conducted on 27.02.2025. The petitioner having submitted a request for adjournment for personal hearing, the same was not considered by respondent No.1, who proceeded to pass the impugned assessment order without providing an opportunity for personal hearing to the petitioner, who is before this Court by way of the present petition. 4. The aforesaid facts and circumstances will clearly indicate that respondent No.1 has proceeded to pass the impugned - 4 - HC-KAR NC: 2025:KHC:47207 WP No. 9876 of 2025 assessment order without providing an opportunity of personal hearing and consequently, by adopting a justice oriented approach, I deem it just and appropriate to set aside the impugned order and remit the matter back to the concerned 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 orders / notices / Computation Sheet at Annexures – E, E1 and E2 all dated 07.03.2025 passed / issued by 1st respondent are hereby set aside. (iii) The matter is remitted back to the 1st respondent for reconsideration afresh in accordance with law from the stage of petitioner submitting its reply to the notice dated 17.02.2025. (iv) Liberty is reserved in favour of the petitioner to submit replies, documents etc., which shall be considered by the 1st respondent, who shall provide - 5 - HC-KAR NC: 2025:KHC:47207 WP No. 9876 of 2025 sufficient and reasonable opportunity to the petitioner and hear them and proceed further in accordance with law. Sd/- (S.R.KRISHNA KUMAR) JUDGE SV List No.: 2 Sl No.: 39