- 1 - HC-KAR NC: 2025:KHC:26490 WP No. 18696 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 16TH DAY OF JULY, 2025 BEFORE THE HON'BLE MR. JUSTICE SURAJ GOVINDARAJ WRIT PETITION NO.18696 OF 2025 (T-IT) BETWEEN: ENCORA INNOVATION LABS INDIA PRIVATE LIMITED (REGISTERED UNDER COMPANIES ACT) NO.10, BRIGADE SOUTH PARADE, BANGALORE NORTH, BANGALORE-560001 PAN NO.AABC6817E, REPRESENTED HEREIN BY ITS DIRECTOR, MR. PHILIP PETER POTHAN. …PETITIONER (BY SRI TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, NEW DELHI-110003. 2. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 2(2)(1), BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE-560095. 3. PRINCIPAL COMMISSIONER OF INCOME-TAX – BENGALURU-2, BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE-560095. …RESPONDENTS (BY SRI E.I. SANMATHI & M. DILIP, ADVOCATES) Digitally signed by SHWETHA RAGHAVENDRA Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:26490 WP No. 18696 of 2025 THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE FINAL ASSESSMENT ORDER DATED 30.03.2025 (ANNEXURE -G) BEARING DIN ITBA/AST/S/143(3)/2024-25/1075282470(1) PASSED BY THE 1ST RESPONDENT FOR THE ASSESSMENT YEAR 2022-23 AND ETC. THIS PETITION COMING ON FOR FINAL HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE SURAJ GOVINDARAJ ORAL ORDER 1. Sri.E.I.Sanmathi., learned counsel is directed to accept notice for respondents No.1 to 3. 2. The petitioner is before this Court seeking for the following reliefs. a. Quashing the final assessment order dated 30.03.2025 (Annexure-G) bearing DIN ITBA/AST/S/143(3)/2024-25/1075282470(1) passed by the 1st respondent for the assessment year 2022-23; b. Quashing the notice dated 30.03.2025 (Annexure- H) bearing DIN ITBA/AST/S/156/2024- 25/1075282796(1) issued by the 1st Respondent for the assessment year 2022-23; c. Quashing the notice dated 30.03.2025 (Annexure-J) bearing DIN ITBA/PNL/S/270A/2024- 25/1075282893(1) issued by the 1st respondent for the assessment year 2022-23; d. Pass such other or further orders as this Hon’ble Court may deem fit in the facts and circumstances of the case, in the interests of justice and equity. - 3 - HC-KAR NC: 2025:KHC:26490 WP No. 18696 of 2025 3. The short grievance of the petitioner in the present matter is that the Assessing Officer could not have gone ahead and passed orders, when the petitioner had submitted a dispute before the Dispute Resolution Panel. This aspect has been dealt with by this Court in WP No.12184 of 2025 dated 4.7.2025 in Kawasaki Manufacturing (India) Vs. Assessment Unit & Ors., wherein this Court has categorically come to a conclusion that when a proceedings are pending before the Dispute Resolution Panel the Assessing Officer ought to stay his hands and await the decision of the Dispute Resolution Panel. Hence, I pass the following; ORDER i. The writ petition is allowed. ii. A certiorari is issued, a final assessment order dated 30.03.2025 bearing DIN ITBA/AST/S/143(3)/2024- - 4 - HC-KAR NC: 2025:KHC:26490 WP No. 18696 of 2025 25/1075282470(1) passed by respondent No.1 at Annexure-G, notice dated 30.03.2025 bearing DIN ITBA/AST/S/156/2024-25/1075282796(1) issued by Respondent No.1 at Annexure-H and notice dated 30.03.2025 bearing DIN ITBA/PNL/S/270A/2024- 25/1075282893(1) issued by respondent No.1 at Annexure-J, are hereby quashed. iii. The Assessing Authority shall await the decision of the Dispute Resolution Panel and thereafter take up such proceedings as are permissible under law. SD/- (SURAJ GOVINDARAJ) JUDGE SR List No.: 1 Sl No.: 56