- 1 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 19TH DAY OF MAY, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND WRIT APPEAL NO. 2116 OF 2025 (T-IT) C/W WRIT APPEAL NO. 2114 OF 2025 WRIT APPEAL NO. 28 OF 2026 WRIT APPEAL NO. 118 OF 2026 WRIT APPEAL NO. 154 OF 2026 WRIT APPEAL NO. 160 OF 2026 WRIT APPEAL NO. 164 OF 2026 WRIT APPEAL NO. 181 OF 2026 WRIT APPEAL NO. 188 OF 2026 WRIT APPEAL NO. 191 OF 2026 WRIT APPEAL NO. 196 OF 2026 WRIT APPEAL NO. 200 OF 2026 WRIT APPEAL NO. 206 OF 2026 Digitally signed by VINUTHA B S Location: High Court of Karnataka - 2 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS WRIT APPEAL NO. 208 OF 2026 WRIT APPEAL NO. 209 OF 2026 WRIT APPEAL NO. 211 OF 2026 WRIT APPEAL NO. 212 OF 2026 WRIT APPEAL NO. 213 OF 2026 WRIT APPEAL NO. 214 OF 2026 WRIT APPEAL NO. 215 OF 2026 WRIT APPEAL NO. 216 OF 2026 WRIT APPEAL NO. 217 OF 2026 WRIT APPEAL NO. 220 OF 2026 WRIT APPEAL NO. 336 OF 2026 WRIT APPEAL NO. 412 OF 2026 WRIT APPEAL NO. 413 OF 2026 WRIT APPEAL NO. 414 OF 2026 WRIT APPEAL NO. 415 OF 2026 WRIT APPEAL NO. 497 OF 2026 WRIT APPEAL NO. 602 OF 2026 WRIT APPEAL NO. 610 OF 2026 WRIT APPEAL NO. 615 OF 2026 WRIT APPEAL NO. 624 OF 2026 WRIT APPEAL NO. 625 OF 2026 WRIT APPEAL NO. 658 OF 2026 - 3 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS WRIT APPEAL NO. 659 OF 2026 WRIT APPEAL NO. 664 OF 2026 WRIT APPEAL NO. 748 OF 2026 WRIT APPEAL NO. 749 OF 2026 WRIT APPEAL NO. 757 OF 2026 WRIT APPEAL NO. 771 OF 2026 WRIT APPEAL NO. 819 OF 2026 WRIT APPEAL NO. 821 OF 2026 WRIT APPEAL NO. 825 OF 2026 WRIT APPEAL NO. 826 OF 2026 WRIT APPEAL NO. 827 OF 2026 WRIT APPEAL NO. 828 OF 2026 WRIT APPEAL NO. 829 OF 2026 WRIT APPEAL NO. 835 OF 2026 WRIT APPEAL NO. 838 OF 2026 WRIT APPEAL NO. 842 OF 2026 WRIT APPEAL NO. 854 OF 2026 WRIT APPEAL NO. 1051 OF 2026 WRIT APPEAL NO. 1053 OF 2026 WRIT APPEAL NO. 1054 OF 2026 WRIT APPEAL NO. 1055 OF 2026 WRIT APPEAL NO. 1056 OF 2026 - 4 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS WRIT APPEAL NO. 1057 OF 2026 WRIT APPEAL NO. 1058 OF 2026 WRIT APPEAL NO. 1059 OF 2026 WRIT APPEAL NO. 1066 OF 2026 WRIT APPEAL NO. 1074 OF 2026 WRIT APPEAL NO. 1075 OF 2026 WRIT APPEAL NO. 1080 OF 2026 WRIT APPEAL NO. 1087 OF 2026 WRIT APPEAL NO. 1098 OF 2026 WRIT APPEAL NO. 1099 OF 2026 WRIT APPEAL NO. 1105 OF 2026 WRIT APPEAL NO. 1106 OF 2026 WRIT APPEAL NO. 1111 OF 2026 IN WA No.2116 OF 2025 BETWEEN: 1. THE INCOME TAX OFFICER INTERNATIONAL TAXATION WARD 1(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 2. THE INCOME TAX OFFICER INTERNATIONAL TAXATION - 5 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS WARD - 2(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 3. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIVIC CENTRE, E-2 BLOCK NEW DELHI 110 002 …APPELLANTS (BY SRI. ARVIND KAMATH, ADDL. SOLICITOR GENERAL A/W SRI. E.I. SANMATHI, SR. STANDING COUNSEL) AND: SUJATHA RAMESH W/O RAMESH S KRISHNAMAGARU AGED ABOUT 65 YEARS 6386, DESSERT FLAME DRIVE SAN JOSE, CALIFORNIA USA 95120 PAN: AWGPR0972G (REPRESENTED BY HER CONSTITUTED ATTORNEY SWARAJ SATHYANARAYAN S/O T. SATHYANARAYAN AGED ABOUT 53 YEARS NO.299, VINAYA MARGA SIDDHARTHA NAGAR MYSORE-570 011 …RESPONDENT (BY SRI. HEMANT VENKATRAJ PAI AND SMT. LOCHANA S. BABU, ADVOCATES) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO SET ASIDE THE ORDER DATED 24.09.2025 IN WRIT PETITION No.32640 OF 2024 (T-IT) PASSED BY THE HON’BLE LEANRED SINGLE JUDE AND GRANT SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT - 6 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS UNDER THE FACTS CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE. IN WA No.2114 OF 2025 BETWEEN: 1. THE DEPUTY COMMISSINER OF INCOME TAX CIRCLE 4(1)(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 2. THE CHIEF COMMISSIONER OF INCOME TAX-1, BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 …APPELLANTS (BY SRI. E.I.SANMATHI, SR. STANDING COUNSEL) AND: RAMACHANDRA REDDY RAVI KUMAR S/O LATE SRI. GOVINDAPPA AGED ABOUT 56 YEARS NO.736/44, 1ST CROSS CHOWDESHWARI LAYOUT MARATHAHALLI, HAL POST BENGALURU-560 037 …RESPONDENT (BY SRI. ANNAMALAI S, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO SET ASIDE THE ORDER DATED - 7 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 28.08.2025 IN WRIT PETITION No.28182 OF 2024 (T-IT) PASSED BY THE HON’BLE LEANRED SINGLE JUDE AND GRANT SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT UNDER THE FACTS CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE. IN WA No.28 OF 2026 BETWEEN: THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2) BANGALORE C.R. BUILDING, QUEEN’S ROAD BENGALURU-560 001 …APPELLANT (BY SRI. RAVI RAJ Y.V., SR. STANDING COUNSEL A/W SRI. DILIP M, STANDING COUNSEL) AND: SRI. ANAND GOLLAHALLI SHIVAPRASAD S/O SRI. DR.G. SHIVAPRASAD AGED ABOUT 51 YEARS 1, SIDDHARTHANAGAR TUMKUR-572 102 REPRESENTED R/AT 253 17TH CROSS, SADASHIVA NAGAR BENGALURU-560 080 …RESPONDENT (BY SRI. VENKATESH G, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO SET ASIDE THE ORDER PASSED BY THE SINGLE JUDE IN WRIT PETITION NO.13471/2025 DATED 08.09.2025 AND PASS SUCH OTHER SUITABLE ORDERS. - 8 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS IN WA No.118 OF 2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-3(2) 3RD FLOOR, C.R. BUILDING QUEEN'S ROAD BENGALURU-560 001 2. THE ADDL. COMMISSIONER OF INCOME TAX CENTRAL RANGE-3 C.R. BUILDING, 3RD FLOOR QUEEN'S ROAD BENGALURU-560 001 3. THE PR. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, BENGALURU C.R. BUILDING, 3RD FLOOR QUEEN'S ROAD BENGALURU-560 001 …APPELLANTS (BY SRI. RAVI RAJ Y.V, SR. STANDING COUNSEL A/W SRI. DILIP M, STANDING COUNSEL) AND: M/S DIVYASREE TARBUS BUILDERS PVT. LTD., A COMPANY INCORPORATED UNDER THE INDIAN COMPANIES ACT, 1956 REPRESENTED BY ITS DIRECTOR MR. G.P. BALAJI DIVYASREE CHAMBERS WING-A, NO.11, O SHAUGNESSY ROAD BANGALORE-560 025 …RESPONDENT (BY SRI. AVINASH MALLYA U ADVOCATE) - 9 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO SET ASIDE THE ORDER PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.12089/2025 DATED 24/09/2025 AND PASS SUCH OTHER SUITABLE ORDERS. IN WA No.154 OF 2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 3(2)(1), BMTC BUILDING 80 FT ROAD, 6TH BLOCK KORAMANGALA, BENGALURU KARNATAKA-560 095 2. CENTRAL BOARD OF DIRECT TAXES CENTRAL SECRETARIAT NORTH BLOCK, NEW DELHI - 110 001 REPRESENTED BY THE ADDITIONAL/ JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER/NATIONAL FACELESS ASSESSMENT CENTRE …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: RAYASHETTYPURA CHIKKLIGEGOWDA RAVISH AGED ABOUT 36 YEARS NO.274, 9TH MAIN, 4TH A BLOCK RPC LAYOUT, VIJAYANAGAR BENGALURU-560 040 …RESPONDENT (BY SRI. ASHOK KULKARNI, ADVOCATE) - 10 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 24/10/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.31674/2025 AND PASS SUCH OTHER ORDER. IN WA No.160 OF 2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BENGALURU 2ND FLOOR, BMTC BUILDING 80 FEET ROAD, 6TH BLOCK KORMANGALA, BENGALURU-560 095 2. THE ADDITIONAL COMMISSIONER OF INCOME TAX RANGE-3 BENGALURU, 2ND FLOOR BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, KORMANGALA BENGALURU-560 095 3. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX-3, BENGALURU 2ND FLOOR, BMTC BUILDING 80 FEET ROAD, 6TH BLOCK KORMANGALA, BENGALURU-560 095 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: GMR HYDERABAD VIJAYAWADA EXPRESSWAYS PRIVATE LIMITED HAVING ITS ADDRESS AT NO. 25/1 - 11 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS SKIP HOUSE, MUSEUM ROAD BENAGLURU-560 025 REPRESENTED BY ITS DIRECTOR MR. OBILISETTY BANGARU RAJU …RESPONDENT (BY SRI. BALARAM R. RAO, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 04.11.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 33180 OF 2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA No.164 OF 2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD-3(2)(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK KORAMANGALA, BENGALURU-560 095 2. THE INCOME TAX OFFICER WARD – 5(1)(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK KORAMANGALA, BENGALURU-560 095 3. THE PR. CHIEF COMMISSIONER OF INCOME TAX (PCCIT) KARNATAKA AND GOA CENTRAL REVENUE BUILDING QUEEN’S ROAD, BENGALURU-560 001 …APPELLANTS (BY SRI. RAVI RAJ Y.V, SR. STANDING COUNSEL A/W SRI. DILIP M, STANDING COUNSEL) - 12 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS AND: CHANNEGOWDA SUKANYA VINAYKUMAR S/O C. CHANNEGOWDA AGED ABOUT 40 YEARS NO.35, AMMA NILAYA, 2ND CROSS CHANDRA LAYOUT BENGALURU-560 040 …RESPONDENT (BY SRI. CHYTHANYA K.K, SR. COUNSEL FOR SRI. TATA KRISHNA, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO SET ASIDE THE ORDER PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 11194/2023 (T-IT) DATED 28.08.2025 AND PASS SUCH OTHER SUITABLE ORDERS AS THIS HON’BLE COURT DEEMS FIT ON THE FACTS AND CIRCUMSTANCES OF THE CASE. IN WA No.181 OF 2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD-3(3)(1), BENGALURU HMT BHAWAN, NO.59, BELLARY ROAD GANGANAGAR BENGALURU-560 032 2. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX-3 BENGALURU, 2ND FLOOR BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, KORMANGALA BENGALURU-560 095 3. ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE - 13 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS NO.401, 2ND FLOOR, E-RAMP JAWAR LAL NEHRU STADIUM DELHI-110 003 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: SHANKARANARAYANA SUDARSHAN S/O SHANKARANARAYANA AGED ABOUT 59 YEARS NO. 007, VISHWABHARATHI KUTIR OPP. RMC, TUMKUR ROAD YESHWANTHPUR BENGALURU-560 022 …RESPONDENT (BY SRI. HEMANT VENKATRAY PAI AND SMT. LOCHANA S BABU, ADVOCATES) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALOW THE APPEAL AND SET ASIDE THE ORDER DATED 24.09.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 7008 OF 2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA No.188 OF 2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 - 14 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 2. THE ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 3 BENGALURU, 2ND FLOOR BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX 3, BENGALURU 5TH FLOOR, BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: GMR VEMAGIRI POWER GENERATION LTD (UNDER COMPANIES ACT, 1956) HAVING ITS ADDRESS AT NO.25/1 SKIP HOUSE, MUSEUM ROAD BENGALURU-560 025 REPRESENTED BY ITS DIRECTOR MR. NIKHIL DUJARI AGED ABOUT 51 YEARS PAN: AABCV1684R …RESPONDENT (BY SRI. BALARAM R. RAO ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 05.11.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 33348 OF 2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, - 15 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA No.191 OF 2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 2. THE JOINT/ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 3(1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU-560 095 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: M/S. NAVNIDHI INFRASTRUCTURE PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 REP. BY ITS DIRECTOR SRI. NAVEEN KUMAR SARAWGI S/O SRI. B. BHAG CHAND SARAWGI AGED ABOUT 50 YEARS C/O BIMAL AUTO AGENCY 60/2, WHITEFIELD ROAD MAHADEVAPURA, BENAGLURU-560 048 …RESPONDENT (BY SRI. MADHUSUDHAN U.A, ADVOCATE) - 16 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 13/10/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.25758/2025 AND PASS SUCH OTHER ORDER. IN WA No.196 OF 2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(1)(1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 2. THE CHIEF COMMISSIONER OF INCOME TAX 1 CENTRAL REVENUE BUILDING QUEENS ROAD, BENGALURU 560 001 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: M/S. HI-Q ELECTRONICS PRIVATE LIMITED (A PRIVATE LIMITED COMPANY INCORPORATED UNDER THE COMPANIES ACT 1956) NO.693, 3RD FLOOR, GEETHANJALI COMPLEX 15TH CROSS JP NAGAR, 2ND PHASE BENGALURU-560 078 KARNATAKA REPRESENTED BY ITS DIRECTOR SHRI. SENDYL VENKATACHALAM …RESPONDENT (BY SRI. ASHOK KULKARNI ADVOCATE) - 17 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28.08.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 25404 OF 2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA No.200 OF 2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, OFFICE OF THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BMTC BUILDING 80 FEET ROAD, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 2. THE CHIEF COMMISSIONER OF INCOME TAX, BENGALURU - 1 CENTRAL REVENUE BUILDING QUEENS ROAD, BENGALURU-560 001 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: JAYMALA NAGARAJA RAO W/O LATE SRI. R. NAGARAJA RAO AGED ABOUT 73 YEARS 18, 5TH CROSS, SHANKARMUTT ROAD SHANKARAPURAM, BENGALURU-560 004 …RESPONDENT (BY SRI. ANNAMALAI S, ADVOCATE) - 18 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28/08/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.14155/2024 AND PASS SUCH OTHER ORDER. IN WA No.206 OF 2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU-560 095 2. THE CHIEF COMMISSIONER OF INCOME TAX - 1, CENTRAL REVENUE BUILDING, QUEENS ROAD BENGALURU-560 001 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: M/S. HASSAN MANGALORE RAIL DEVELOPMENT COMPANY LIMITED 7TH FLOOR, MSIL HOUSE, 36 CUNNINGHAM ROAD, BENGALURU-560 052 (A COMPANY LIMITED UNDER REGISTERED COMPANIES ACT, 1956) REP. BY ITS COMPANY SECRETARY SHRI. SHARATH BABU R.M 3763, 4TH A MAIN, E BLOCK 2ND STAGE, RAJAJINAGARA BENGALURU-560 021 …RESPONDENT (BY SRI. HEMANT VENKATRAJ PAI AND SMT. LOCHANA S. BABU, ADVOCATES) - 19 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 24/09/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.33305/2024 AND PASS SUCH OTHER ORDER. IN WA No.208 OF 2026 BETWEEN: 1. THE ASSESSING OFFICER DEPARTMENT OF INCOME TAX WARD 5(3) BENGALURU 2. THE ASSESSMENT UNIT INCOME TAX DEPARTMENT NATIONAL FACELESS ASSESSMENT CENTRE 2ND FLOOR, E-RAMP JAWAHARLAL NEHRU STADIUM NEW DELHI-110 003 3. UNION OF INDIA THROUGH ITS SECRETARY MINISTRY OF FINANCE DEPARTMENT OF REVENUE NORTH BLOCK, NEW DELHI - 110 001 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: SUGHOSH NAGENDRA S/O LATE H.S. NAGENDRA AGED ABOUT 50 YEARS, RESIDING AT 14/36, 3RD MAIN - 20 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS PARAMHAMSA ROAD, YADAVAGIRI MYSORE-570 020 …RESPONDENT (BY SRI. B.N. MAHESH CHANDRA, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 18/11/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.33872/2024 AND PASS SUCH OTHER ORDER. IN WA No.209 OF 2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 2. THE CHIEF COMMISSIONER OF INCOME TAX BENGALURU -1 CR BUILDING, NO.1, QUEEN’S ROAD BENGALURU 560 001 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: NTT DATA INFORMATION PROCESSING SERVICES PRIVATE LIMITED (FOR THE MERGED ENTITY NTT DATA GLOBAL DELIVERY SERVICES PVT LTD INTO WHICH, NTT DATA INDIA ENTERPRISES APPLICATION SERVICES - 21 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS PRIVATE LIMITED PREVIOUSLY MERGED) A COMPANY INCORPORATED UNDER THE COMPANIES ACT 1956 HAVING OFFICE AT PLOT NO. 178 EPIP PHASE II WHITEFIELD INDUSTRIAL AREA BANGALORE 560 066 REPRESENTED HEREIN BY ITS SENIOR DIRECTOR MR. SANTHOSH KARAMANGATTIL …RESPONDENT (BY SMT. TANMAYEE RAJKUMAR, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 11.11.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 17392 OF 2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA No.211 OF 2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 2. THE CHIEF COMMISSIONER OF INCOME TAX - 1, BENGALURU CENTRAL REVENUE BUILDING QUEENS ROAD BENGALURU-560 001 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) - 22 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS AND: BALAJI RAMAN S/O SRI. S. RAMAN AGED ABOUT 58 YEARS C-1406, MANTRI TRANQUIL APARTMENT, GUBBALALA GATE BENGALURU- 560 061 …RESPONDENT (BY SRI. MADHUSUDAN, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28.08.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 16764 OF 2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA No.212 OF 2026 BETWEEN: THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 …APPELLANT (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: GMR SEZ AND PORT HOLDINGS LIMITED STATUS COMPANY (UNDER COMPANIES ACT 1956) HAVING ITS ADDRES AT NO.25/1 - 23 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS SKIP HOUSE, BANGALORE-560 025 REPRESENTED BY IT DIRECTOR SANJAY KUMAR JAIN AGED ABOUT 56 YEARS …RESPONDENT (BY SRI. BALRAM R. RAO, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 04/11/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.32829/2024 AND PASS SUCH OTHER ORDER. IN WA No.213 OF 2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD-5(2)(1), BANGALORE-560 095 2. NATIONAL FACELESS ASSESSMENT CENTRE REP. BY ADDL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER, INCOME TAX DEPARTMENT MINISTRY OF FINANCE, ROOM NO.401 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM NEW DELHI-110 003 3 . THE PRINCIPAL COMMISSIONER OF INCOME TAX-3, THE OFFICE OF THE PRINCIPAL COMMISSIONER OF INCOME TAX-3, BMTC BUILDING KORAMANGALA BENGALURU 560 095 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) - 24 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS AND: SRI. NAGENDRA CREDIT CO-OPERATIVE SOCIETY LIMITED A REGISTERED CO-OPERATIVE SOCIETY REPRESENTED BY ITS CEO SRI. SIDDESHA K.S AGED ABOUT 45 YEARS 368/A, 6TH MAIN ROAD NAGENDRA BLOCK BANGALORE-560 050 PAN. AADTS4884P …RESPONDENT (BY SRI. RAVI SHANKAR S.V, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 08.09.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 14686 OF 2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA No.214 OF 2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 2(4) MYSORE-570 010 2. THE INCOME TAX OFFICER WARD 1(1) MYSORE-570 010 3. NATIONAL FACELESS ASSESSMENT CENTRE ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/ - 25 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS INCOME TAX OFFICER INCOME TAX DEPARTMENT MINISTRY OF FINANCE NO.401,2ND FLOOR, JAWAR LAL NEHRU STADIUM, DELHI 110 003 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: SRI. MAMBALLI SUNDAR VIJAYENDRA S/O LATE P. SUNDAR AGED ABOUT 47 YEARS NO.01, SUNDATAGIRI, T.N.PURA ROAD SIDDARTHANAGAR MYSORE-570 010 …RESPONDENT (BY SRI. RAVI SHANKAR S.V AND SRI. SHARAN S BANAD, ADVOCATES) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 04.09.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No.23251 OF 2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA No.215 OF 2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 3(1)(1), BMTC BUILDING 80 FT ROAD, 6TH BLOCK KORAMANGALA, BENGALURU KARNATAKA-560 095 - 26 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 2. NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT GOVERNMENT OF INDIA MINISTRY OF FINANCE NEW DELHI - 110 00 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: RUKMINI VENKATAPPA W/O RAMAKRISHNA C.T AGED ABOUT 69 YEARS NO.16, 7TH CROSS, MAGADI ROAD CHOLUR PALYA BANGALORE NORTH - 560 023 …RESPONDENT (BY SRI. PRAKASH D, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 19.11.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 21864 OF 2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA No.216 OF 2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD- AND TPS AAYAKAR BHAVAN, 2ND STAGE - 27 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS VIJAY NAGAR, BELUR ROAD HASSAN-573 201 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3 BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU-560 095 3. THE ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE REP. BY ADDL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER INCOME TAX DEPARTMENT MINISTRY OF FINANCE, ROOM NO 401 2ND FLOOR, E-RAMP JAWAHARLAL NEHRU STADIUM NEW DELHI - 110 003 …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: SHRI. MANGALAPURA DASHARATHY ASHOK NAG S/O M.V. DASHARATHY AGED ABOUT 39 YEARS MATHRUSHREE SERVICE STATION MANGALAPURA, KASABA HOBLI HN PURA TALUK, MUDALAHIPPE HASSAN-573 211 …RESPONDENT (BY SRI. HEMANT VENKATRAJ PAI AND SMT. LOCHANA S. BABU, ADVOCATES) - 28 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 18/09/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.18201/2025 AND PASS SUCH OTHER ORDER. IN WA No.217 OF 2026 BETWEEN: …APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) 1. ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE NO.401, 2ND FLOOR JAWAR LAL NEHRU STADIUM DELHI 110 003 2. THE INCOME TAX OFFICER WARD - 3(2)(1) BENGALURU BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, KORMANGALA BANGALORE 560 095 3. THE INCOME TAX OFFICER WARD 5(1)(1) BENGALURU 2ND FLOOR, BMTC BUILDING 80 FEET ROAD, 6TH BLOCK KORMANGALA BENGALURU 560 095 4. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KARNATAKA AND GOA CR BUILDING, NO.-1, QUEEN ROAD BANGALORE 560 001 - 29 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS AND: MR. BHUVANENDRAGOWDA S/O LATE GAVI RANGE GOWDA AGED ABOUT 63 YEARS RESIDING AT NO. 332, 4TH MAIN ROAD VIJAYANAGAR BANGALORE-560 040 …RESPONDENT (BY SRI. SANDEEP HUILGOL, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 13.11.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 34103 OF 2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA No.220 OF 2026 BETWEEN: 1. CENTRAL BOARD OF DIRECT TAXES THROUGH THE CHAIRPERSON DEPARTMENT OF REVENUE MINISTRY OF FINANCE NORTH BLOCK, NEW DELHI-110 002 2. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(4), BENGALURU 3RD FLOOR, CENTRAL CIRCLE-2(4) C.R. BUILDING, QUEEN'S ROAD BENGALURU-560 001 3. THE DIRECTOR GENERAL OF INCOME TAX (INV.,) CENTRAL REVENUE BUILDING, QUEEN'S ROAD, BENGALURU-560 001 +…APPELLANTS - 30 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: M/S AKHILA BHARTH SRI VASAVI PENUGONDA TRUST REPRESENTED BY ITS TREASURER N.S. SRINIVASA MURTHY S/O. N.K. SUBBAIAH SETTY AGED ABOUT 72 YEARS NO.23A, VASAVI NILAYA SERPENTINE ROAD KUMARA PARK WEST BENGALURU-560 020 …RESPONDENT (BY SRI. ANNAMALAI S, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF KARNATAKA HIGH COURT ACT PRAYING TO SET ASIDE THE ORDER PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.20550/2022 DATED 28/08/2025 AND PASS SUCH OTHER SUITABLE ORDERS AND ETC. IN WA NO. 336/2026 BETWEEN: 1. ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, 2ND FLOOR, JAWAHARLAL NEHRU STADIUM, NEW DELHI-110 003. 2. INCOME TAX OFFICER, WARD 5(2)(1), BANGALORE BMTC BUILDING, 80 FEET ROAD, 6TH ROAD, KORAMANGALA, BANGALORE-590 095. 3. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, - 31 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS BENGALURU - III, BENGALURU, C R BUILDING, NO.1, QUEENS ROAD, BANGALORE-560 001. ..APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. MR ARJUN CHITLUR SHIVAKUMAR S/O. C R SHIVAKUMAR AGED ABOUT 43 YEARS, RESIDING AT NO.22, M T STREET, NETKALLAPPA CIRCLE, BASAVANAGUDI, BENGALURU. ...RESPONDENT (BY SRI. SANDEEP HUILGOL, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 14.11.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.34097/2025 AND PASS SUCH OTHER ORDER. IN WA NO. 412/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 5(3)(3), BANGALORE, 5TH FLOOR, BMTC BUILDING, 80 FT ROAD, 6TH BLOCK KORAMANGALA, BENGALURU, KARNATAKA-560 095. 2. ASSESSMENT UNIT, NATIONAL E- ASSESSMENT CENTRE, INCOME TAX DEPARTMENT MINISTRY OF FINANCE 2ND FLOOR, E- RAMP, - 32 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS JAWAHARLAL NEHRU STADIUM, NEW DELHI-110 003. 3. PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE - 3, 5TH FLOOR, BMTC BUILDING, 80 FT ROAD, 6TH BLOCK KORAMANGALA, BENGALURU, KARNATAKA- 560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. NANDITA ANILKANTH MEHTA D/O ANITHA HANILAL MEHTA, AGED ABOUT 50 YEARS, RESIDING AT: FLAT NO.402B, SRINIVASA CLASSIC, SARJAPUR MAIN ROAD, NEXT TO FIRE STATION, KAIKONDARAHALLI, BANGALORE-560 035. ...RESPONDENT (BY SMT. GIRIJA G.P., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO SET ASIDE THE ORDER PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 32231/2025 (T-IT) DATED 29-10-2025 AND ETC. IN WA NO. 413/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 3(3)(1), HMT BHAWAN, NO. 59, BELLARY ROAD, GANGA NAGAR, BENGALURU-560 032. ...APPELLANT (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) - 33 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS AND: 1. SHIVAMMA W/O SIDDAPPA, RESIDING AT NO.1054, GROUND FLOOR, 5TH BLOCK JANAPRIYA TOWNSHIP, KADABAGERE POST, BENGALURU-562 130. ...RESPONDENT (BY SRI. BALRAM R RAO., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 07/11/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.10103/2025 AND PASS SUCH OTHER ORDER. IN WA NO. 414/2026 BETWEEN: 1. THE INCOME TAX WARD - 1(1), CENTRAL REVENUE BUILDING, 22/16, GOVERNMENT HOUSE ROAD, NAZARBAD, MYSURU- 570 010. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3 BMTC BUILDING, 80 FT ROAD, 6TH BLOCK KORAMANGALA, BENGALURU, KARNATAKA-560 095. 3. NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E-RAMP, - 34 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS JAWAHARLAL NEHRU STADIUM, DELHI-110 003. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. SRI MOHAMMED SAIT RESIDING AT NO.132, 4TH CROSS, BANNI MANTAPA, MYSURU-270 015. ...RESPONDENT (BY SRI. HEMANT VENKATRAY PAI., ADVOCATE AND SMT. LOCHANA S. BABU, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 24/09/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.33109/2024 AND PASS SUCH OTHER ORDER. IN WA NO. 415/2026 BETWEEN: 1. ASSESSMENT UNIT INCOME TAX DEPARTMENT, REP. BY ADDITIONAL/JOINT/DEPUTY/ ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110 003. 2. THE INCOME TAX OFFICER WARD 5(1)(1), BMTC BUILDING, - 35 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 80 FT ROAD, 6TH BLOCK KORAMANGALA, BENGALURU, KARNATAKA-560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. M/S NISHI FOREX AND LEISURE PRIVATE LIMITED REP. BY: SRI. RAM CHANDRA K, R/O NO.536, GROUND FLOOR, AMAR JYOTHI LAYOUT, 100FT ROAD, INTERMEDIATE RING ROAD, DOMLUR, BANGALORE - 560 071. ...RESPONDENT (BY SRI. ANNAMALAI S., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 17/11/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.34260/2025 AND PASS SUCH OTHER ORDER. IN WA NO. 497/2026 BETWEEN: 1. CENTRAL BOARD OF DIRECT TAXES MINISTRY OF FINANCE GOVERNMENT OF INDIA, REPRESENTED BY ITS CHAIRMAN, NORTH BLOCK, NEW DELHI -110 002. 2. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1)(1) BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, - 36 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS KORAMANGALA, BENGALURU-560 095. ...APPELLANTS (BY SRI. RAVI RAJ Y.V., SR. STANDING COUNSEL A/W SRI. DILIP M., STANDING COUNSEL) AND: 1. M/S AMD INDIA PRIVATE LIMITED REPRESENTED BY SRI. NAGENDRA K. PLOT NO.102 AND 103, EXPORT PROMOTION INDUSTRIAL PARK, WHITEFIELD, BENGALURU-560066. ...RESPONDENT (BY SRI. CHYTHANYA K.K., SENIOR COUNSEL FOR SRI. TATA KRISHNA, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT, 1961 PRAYING TO SET ASIDE THE ORDER PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.17352/2022 DATED 28/08/2025 AND ETC. IN WA NO. 602/2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 5(1)(1), BANGALORE BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BENGALUR-560 095. 2. THE CHIEF COMMISSIONER OF INCOME TAX-1 CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU-560 001. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) - 37 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS AND: 1. NORDEX INDIA PRIVATE LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 HAVING ITS OFFICE AT NO. 201, 2ND FLOOR, PRESTIGE EMERALD, NO. 2 (OLD NO. 4), CORPORATION NO. 61, MADRAS BANK ROAD, LAVELLE ROAD, BANGALORE - 560 001 REPRESENTED BY ITS DIRECTOR - FINANCE, CFO, DHARMALA VENKATA RAMANA MURTHY. ...RESPONDENT (BY SMT. TANMAYEE RAJKUMAR, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 29.10.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 31047 OF 2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HONBLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 610/2026 BETWEEN: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU-560 095. ...APPELLANT (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) - 38 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS AND: 1. GOOGLE INDIA PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 HAVING ITS REGISTERED OFFICE AT 4TH AND 5TH FLOOR, RMZ INFINITY NO.3, TOWER E, OLD MADRAS ROAD, BENGLAURU - 560 016 THROUGH IT AUTHORISED SIGNATORY / HEAD OF TAX MR. VINAY MANGLA ...RESPONDENT (BY SRI. AADITH SRIDHAR, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 16/10/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.28484/2025 AND PASS SUCH OTHER ORDER. IN WA NO. 615/2026 BETWEEN: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU-560095. ...APPELLANT (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. GOOGLE INDIA PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 - 39 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS HAVING ITS REGISTERED OFFICE AT 4TH AND 5TH FLOOR, RMZ INFINITY, NO. 3, TOWER E OLD MADRAS ROAD, BENGALURU-560 016 THROUGH IT AUTHORISED SIGNATORY MR. VINAY MANGLA. ...RESPONDENT (BY SRI. AADITH SRIDHAR, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 16.10.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 26476/2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 624/2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(1), BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095. 2. THE JOINT COMMISSIONER OF INCOME TAX - 2, BENGALURU, RANGE 3(1) BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095. 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3, BENGALURU, BMTC BUILDING, 80 FEET ROAD, - 40 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095 ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. M/S NORTHROOF VENTURES PRIVATE LIMITED REPRESENTED BY ITS AUTHORISED SIGNATORY SHRI. RAMESH KARUR RAGHAVENDRAN NO.1/8, 1ST FLOOR, NO.41, CASTLE STREET, OPP. SACRED HEART CHRUCH RICHMOND ROAD, ASHOK NAGAR RICHMOND TOWN, BENGALURU-560 025 ...RESPONDENT (BY SRI. MADHUSUDHAN U.A., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 10/10/2025 PASSED BY THE LEARNED SINGLE JUDE IN WP NO.29554/2025 AND PASS SUCH OTHER ORDER. IN WA NO. 625/2026 BETWEEN: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BENGALURU - 560 095. 2. CHIEF COMMISSIONER OF INCOME TAX-1 BMTC BUILDING, 80 FEET ROAD, - 41 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS KORAMANGALA, BENGALURU - 560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. NIKE INDIA PRIVATE LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 HAVING ITS OFFICE AT 66/1, GROUND AND FIRST FLOOR, OLYMPIA BUILDING, BAGMANE TECH PARK, C.V RAMAN NAGAR BENGALURU - 560 093 REPRESENTED BY ITS DIRECTOR, SUCHITRA BHAT. ...RESPONDENT (BY SMT. TANMAYEE RAJKUMAR, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 11/11/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.19179/2024 AND PASS SUCH OTHER ORDER. IN WA NO. 658/2026 BETWEEN: 1. ASSISTANT/DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 5(1)(1) BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA BENGALURU-560 095. 2. JOINT COMMISSIONER OF INCOME TAX RANGE-3(1), BMTC BUILDING, 80 FEET ROAD, - 42 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 6TH BLOCK, KORAMANGALA, BENGALURU-560095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. PNB METLIFE INDIA INSURANCE COMPANY LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 AND HAVING ITS OFFICE AT UNIT NO.701-702-703 RAHEJA TOWERS, WEST WING BANGALORE-560001 REPRESENTED HEREIN BY ITS MR. SANJEEV SUMAN ASSOCIATE DIRECTOR. ...RESPONDENT (BY SMT. TANMAYEE RAJKUMAR., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 13.10.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 27236/2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 659/2026 BETWEEN: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, - 43 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS KORAMANGALA, BENGALURU-560 095. ...APPELLANT (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. GOOGLE INDIA PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 HAVING ITS REGISTERED OFFICE AT 4TH AND 5TH FLOOR, RMZ INFINITY NO.3, TOWER E, OLD MADRAS ROAD, BENGLAURU-560 016 THROUGH IT AUTHORISED SIGNATORY / HEAD OF TAX MR. VINAY MANGLA ...RESPONDENT (BY SRI. AADITH SRIDHAR, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 16.10.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 28502/2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 664/2026 BETWEEN: 1. PRL. COMMISSIONER OF INCOME TAX BANGALORE-3 HAVING OFFICE AT BMTC BUILDING 80 FEET ROAD, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU-560 095. - 44 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 2. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BENGALURU HAVING OFFICE AT BMTC BUILDING 80 FEET ROAD, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU-560 095. 3. DEPUTY COMMISSIONER OF INCOME TAX DC/ACIT, CIRCLE-5(1)(1), BLR HAVING OFFICE AT BMTC BUILDING 80 FEET ROAD, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU-560 095. 4. NATIONAL FACELESS ASSESSMENT CENTRE ADDITIONAL / JOINT / DEPUTY / ASSISTANT COMMISSIONER OF INCOME TAX / INCOME TAX OFFICER, MINISTRY OF FINANCE 3RD FLOOR, JEEVAN DEEP BUILDING SANSAD MARG, NEW DELHI - 110 001. 5. UNION OF INDIA REPRESENTED BY ITS PRL. SECRETARY MINISTRY OF FINANCE, 3RD FLOOR, JEEVAN DEEP BUILDING, SANSAD MARG, NEW DELHI-110 001. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. MR. PRADEEP KUMAR SHEKAR S/O LATE MR. SHEKAR AGED ABOUT 52 YEARS R/O C501, SALARPURIA SERENITI 5TH MAIN, HSR LAYOUT SECTOR - 7, BENGALURU-560 102. (FORMER DIRECTOR M/S PLG POWER AND INFRA PVT. LTD. - 45 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS STRUCK-OFF FROM THE REGISTRAR OF COMPANIES W.E.F., 08.11.2019). 2. MR. SHANKAR SURESH, S/O SRI. H. SHANKAR SHASTRI AGED ABOUT 51 YEARS R/O NO. 33, 22ND MAIN PADMANABHA NAGAR, BSK II STAGE BENGALURU - 560 070. (FORMER DIRECTOR M/S PLG POWER AND INFRA PVT. LTD. STRUCK-OFF FROM THE REGISTRAR OF COMPANIES W.E.F., 08.11.2019) ...RESPONDENTS (BY SRI. BHARATH KUMAR V., ADVOCATE FOR R1 AND R2) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 03.12.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 36426/2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 748/2026 BETWEEN: 1. THE DEPUTY COMMISSIONER/ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 5(1)(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALRUU -560 095. 2. THE JOINT COMMISSIONER OF INCOME TAX, RANGE 3(1) BMTC BUILDING, 80 FEET ROAD - 46 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALRUU -560095. 3. THE DEPUTY /ASSISTANT DIRECTOR OF INCOME TAX, (INV.) 2(4) C R BUILDINGS ANNEXEX, NO. 1 QUEENS ROAD BENGALRUU -560001. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. M/S. OZONE ELEGANT DEVELOPERS PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT 2013 REPRESENTED BY ITS DIRECTOR SRI MEDIPALLI SREEHARI S/O SRI MEDIPALLI PRATHAP NAIDU AGED ABOUT 53 YEARS NO. 35/1, 2ND FLOOR YELLAPPA CHETTY LAYOUT CIVIL STATION, ULSOOR ROAD BENGALRUU -560042 PAN: AADC03705C. ...RESPONDENT (BY SRI. ANNAMALAI S., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 04.09.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No.21221 OF 2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. - 47 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS IN WA NO. 749/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 5(1)(1) BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU-560 095. 2. THE PRINCIPAL COMMISSIONER OF INCOME-TAX 1, BENGALURU, CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001 ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. GITHMAL MODIRAM MANOHAR LAL SON OF SRI. MODIRAM JI MEHTA, AGED ABOUT 73 YEARS, 113/B, MEHTA JEWELLERS, MAGADI MAIN ROAD, BENGALURU-560 023. ..RESPONDENT (BY SRI. MADHUSUDHAN U.A., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28/08/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.35113/2024 AND PASS SUCH OTHER ORDER. IN WA NO. 757/2026 BETWEEN: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX - 48 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS CIRCLE - 1(1) & TPS, MYSURU 1ST FLOOR, AYAKAR BHAVAN REAC, MYSURU-570 008. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3, BENGALURU, BMTC BUILDING 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 3. ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR E-RAMP, JAWARLAL NEHRU STADIUM DELHI-110 003. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. MUDIGUNDAM SRINIVASAMURTHY MANJUNATH S/O M.C. SRINIVASA MURTHY AGED ABOUT 43 YEARS 1296, MIG, 6TH CROSS NEAR PUJA MARKETING VIVEKANANDA NAGAR MYSURU-570 023. ...RESPONDENT (BY SRI. HEMANT VENKATRAY PAI., ADVOCATE SMT. LOCHANA S. BABU, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 24.09.2025 PASSED - 49 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS BY THE LEARNED SINGLE JUDGE IN WP No. 4377 OF 2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 771/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 3(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU - 3, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 3. THE ADDITIONAL COMMISSIONER OF INCOME TAX RANGE 3(1) BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 4. THE DEPUTY / ASSISTANT DIRECTOR OF INCOME TAX, (INV.) 2(4) C.R. BUILDINGS ANNEXE, NO. 1, QUEENS ROAD, BENGALURU - 560 001. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. M/S. OZONE ELEGANT DEVELOPERS PRIVATE LIMITED INCORPORATED UNDER COMPANIES ACT, 2013 REPRESENTED BY ITS DIRECTOR, - 50 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS SRI MEDIPALLI SREEHARI S/O SRI MEDIPALLI PRATHAP NAIDU, AGED ABOUT 53 YEARS, PRESENTLY AT NO. 35/1, 2ND FLOOR, YELLAPPA CHETTY LAYOUT, CIVIL STATION, ULSOOR ROAD, BENGALURU - 560 042 PAN: AADCO3705C. ...RESPONDENT (BY SRI. ANNAMALAI S., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 04/09/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.19658/2024 AND PASS SUCH OTHER ORDER. IN WA NO. 819/2026 BETWEEN: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. ..APPELLANT (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. M/S. H.M. TOWERS PRIVATE LIMITED NO.14, H M GENEVA HOUSE, CUNNINGHAM ROAD, BENGALURU - 560 001 REPRESENTED BY ITS DIRECTOR, SRI. M. J. SIWANI, - 51 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS S/O. LATE J. K. SIWANI, AGED ABOUT 61 YEARS. ...RESPONDENT (BY SRI. CHYTHANYA K.K., SENIOR COUNSEL FOR SRI. TATA KRISHNA AND SHARATH S., ADVOCATES) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28/08/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.14767/2024 AND PASS SUCH OTHER ORDER. IN WA NO. 821/2026 BETWEEN: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BANGALORE BMTC BUILDING 80 FEET ROAD, KORAMANGALA, BENGALURU -560095. 2. JOINT/ADDITIONAL COMMISSIONER OF INCOME TAX RANGE 3 (1), BANGALORE BMTC BUILDING, 80 FEET ROAD KORAMANGALA BENGALURU- 560095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. INFOSYS LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT 1956 HAVING OFFICE AT PLOT NO.44 KONAPPANA AGRAHARA, HOSUR ROAD ELECTRONIC CITY BANGALORE -560100 - 52 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS REP. BY ITS AUTHORIZED SIGNATORY MR. ANAND JAISWAL. ...RESPONDENT (BY SMT. TANMAYEE RAJKUMAR, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 13.10.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 28823/2025 (T-RES) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 825/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 5(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3, BANGALORE, 6TH BLOCK, NEAR KHB GAMES VILLAGE, BENGALURU - 560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. VANITHA GOVINDAPPA DAUGHTER OF LATE SRI. GOVINDAPPA, AGED ABOUT 54 YEARS, NO. 707, 7TH MAIN, HAL 2ND STAGE, - 53 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS INDIRANAGAR, BENGALURU - 560 038. ...RESPONDENT (BY SRI. MADHUSUDHAN U.A., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 08/09/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.18965/2024 AND PASS SUCH OTHER ORDER. IN WA NO. 826/2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1) (1), BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU 560 095. 2. THE CHIEF COMMISSIONER OF INCOME TAX -1 CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001. 3. THE JOINT COMMISSIONER OF INCOME TAX, CIRCLE 1, TPR INCOME TAX OFFICE NO.121, ADAMS BUILDINGS, SIXTY FEET ROAD TIRUPUR - 641 602. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) - 54 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS AND: 1. SRI. HIREN ATUL RUPARELIA SON OF SRI ATUL A RUPARELIA AGED ABOUT 47 YEARS NO.142/B, 1ST FLOOR NEAR HOTEL E -INN, 1ST PHASE BOMMASANDRA INDUSTRIAL AREA BANGALORE - 560 099. ...RESPONDENT (BY SRI. VENKATESH G., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28/08/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.19581/2024 AND PASS SUCH OTHER ORDER. IN WA NO. 827/2026 BETWEEN: 1. THE DEPUTY COMMISSIONER/ ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 5(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 2. THE JOINT / ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 3(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE 560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) - 55 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS AND: 1. ORACLE SOLUTION SERVICES (INDIA) PVT LTD A COMPANY INCORPORATED UNDER THE COMPANIES ACT 1956, REPRESENTED BY ITS AUTHORIZED SIGNATORY SRI. UMA SHANKAR GAUTAM, SON OF LATE SRI. OM PRAKASH SHARMA, AGED ABOUT 49 YEARS, HAVING ITS REGISTERED OFFICE AT: BLOCK B LVL 4, NO. 169/1, ORACLE TECH HUB, MARTHAHALLI RING ROAD KADUBEESANHALLI, BELLANDUR, BANGALORE - 560 103. ...RESPONDENT (BY SRI. ANNAMALAI S., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 24.09.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 27681/2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 828/2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU-560 095. 2. THE CHIEF COMMISSIONER OF INCOME TAX-1 - 56 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS BENGALURU, CENTRAL REVENUE BUILDING, QUEEN’S ROAD, BENGALURU-560 001. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. M/S INTERNATIONAL AEROSPACE MANUFACTURING PRIVATE LIMITED COMPANY INCORPORATED UNDER COMPANIES ACT, 1956, REPRESENTED BY ITS AUTHORIZED SIGNATORY, SRI. SATISH SIVARAMAN, SON OF SRI. SIVARAMAN, AGED ABOUT 50 YEARS SURVEY NO. 3, VARTHUR HOBLI, BENGALURU RURAL, KARNATAKA-560 037. ...RESPONDENT (BY SRI. ANNAMALAI S., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28.08.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 10890/2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 829/2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1)(1), BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6th BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU 560 095. - 57 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 2. THE CHIEF COMMISSIONER OF INCOME TAX - 1 CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGLAURU-560 001. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. BALAJI RAMAN SON OF SRI. S RAMAN, AGED ABOUT 58 YEARS, C-1406, MANTRI TRANQUIL APARTMENT, GUBBALALA GATE BENGLAURU-560 061. ...RESPONDENT (BY SRI. MADHUSUDHAN U.A., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28.08.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 17003/2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 835/2026 BETWEEN: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1) - BANGALORE BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU-560 095. - 58 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 2. JOINT/ADDITIONAL COMMISSIONER OF INCOME TAX RANGE 3(1), BANGALORE, BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU-560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. INFOSYS LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 HAVING OFFICE AT PLOT NO. 44, KONAPPANA AGRAHARA HOSUR ROAD, ELECTRONIC CITY, BANGALORE - 560 100. REPRESENTED BY ITS AUTHORIZED SIGNATORY MR. ANAND KUMAR JAISWAL. ...RESPONDENT (BY SMT. TANMAYEE RAJKUMAR., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 13.10.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 28391/2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 838/2026 BETWEEN: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BANGALORE BMTC BUILDING, - 59 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 095. 2. JOINT/ADDITIONAL COMMISSIONER OF INCOME TAX RANGE 3(1), BANGALORE, BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. INFOSYS BPM LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 HAVING OFFICE AT PLOT NO.44 KONAPPANA AGRAHARA, HOSUR ROAD ELECTRONIC CITY BANGALORE - 560 100 REPRESENTED BY ITS AUTHORIZED SIGNATORY MR. ANAND KUMAR JAISWAL ...RESPONDENT (BY SMT. TANMAYEE RAJKUMAR., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 13/10/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.28937/2025 AND PASS SUCH OTHER ORDER. IN WA NO. 842/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 5(3)(2), - 60 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS NO. 59, HMT BHAVAN, 4TH FLOOR, BELLARY ROAD, GANGANAGAR, BENGALURU - 560 032. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3, BENGALURU, BMTC BUILDING, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 3. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2ND FLOOR, E- RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. ANANDA RAJU KRISHNAPPA S/O OF S. KRISHNAPPA, AGED ABOUT 43 YEARS, NO.9, 2ND MAIN, 1ST A CROSS, BEHIND AMAR JOTHI PARK, T NAGAR POST, KUPPUSWAMY GARDEN, BENGALURU - 560 032. ...RESPONDENT (BY SRI. HEMANT VENKATRAY PAI., ADVOCATE AND SMT. LOCHANA S. BABU, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 24.09.2025 PASSED - 61 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS BY THE LEARNED SINGLE JUDGE IN WP NO.12788/2025 AND PASS SUCH OTHER ORDER. IN WA NO. 854/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 3(1)(3), BANGALORE BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU-560095. 2. THE PRINCIPAL COMMISSIONER OF INCOME-TAX, BENGALURU-3, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. J B KEMPANNA SHETTY CHARITIES REPRESENTED BY ITS TREASURER SRI. KEMPANNA CHETTY SON OF LATE SRI. ARASAPPA SHETTY AGED ABOUT 70 YEARS, NO. 73, OTC ROAD, NAGRATHAPET MAIN ROAD, BENGALURU – 560002. ...RESPONDENT (BY SRI. SURYA KANTH C.S., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 8.09.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 23541/2024 (T- IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND - 62 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 1051/2026 BETWEEN: 1. INCOME TAX OFFICER WARD 5(1) (1), BENGALURU THE JURISDICTIONAL ASSESSING OFFICER UNDER THE INCOME TAX ACT, 1961 BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 2. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA AND GOA, BENGALURU, THE SPECIFIED AUTHORITY UNDER SECTION 151 OF THE INCOME TAX ACT, 1961 CENTRAL REVENUE BUILDING QUEENS ROAD, BENGALURU- 560 001. 3. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), A CENTRE DESCRIBED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961 ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC). 4. ASSESSMENT UNIT, A UNIT CREATED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 - 63 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC) ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. LATE MRS. NOORUNNISSA BABU REP. BY HER LEGAL REPRESENTATIVE MRS. SHAMEEM BABU, DAUGHTER OF SHRI. N BABU, AGED ABOUT 42 YEARS, NO.96, 3RD CROSS, 7TH BLOCK, KORAMANGALA IND LAYOUT BENGALURU - 560 095. ...RESPONDENT (BY SRI. SHREEHARI KUTSA, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28.08.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 29838/2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 1053/2026 BETWEEN: 1. DEPUTY/ ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - 5(1)(1), BANGALORE, BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 095. 2. CHIEF COMMISSIONER OF INCOME TAX - 1, - 64 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. NIKE INDIA PRIVATE LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 HAVING OFFICE AT 66/1, GROUND AND FIRST FLOOR, OLYMPIA BUILDING, BAGMANE TECH PARK, C.V RAMAN NAGAR, BENGALURU - 560 093 REPRESENTED BY ITS DIRECTOR, SUCHITRA BHAT. ...RESPONDENT (BY SMT. TANMAYEE RAJKUMAR, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 04/11/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.32751/2024 AND PASS SUCH OTHER ORDER. IN WA NO. 1054/2026 BETWEEN: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1) AND TPS, 1ST FLOOR, AYAKAR BHAVAN REAC, MYSURU - 570 008. 2. JOINT COMMISSIONER OF INCOME TAX RANGE-1, 22/16, - 65 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS CENTRAL REVENUE BUILDING NAZARBAD ROAD, MYSURU - 570 008. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. MOHAMMED SAIT SON OF LATE ABDUL AZEEZ SAIT, AGED ABOUT 52 YEARS, NO.132, 4TH CROSS, BANNIMANTAPA, C LAYOUT, MYSURU - 570 015. ...RESPONDENT (BY SRI. HEMANT VENKATRAY PAI., ADVOCATE AND SMT. LOCHANA S. BABU, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 31/10/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.23131/2025 AND PASS SUCH OTHER ORDER. IN WA NO. 1055/2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1) BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU - 560 095. 2. THE CHIEF COMMISSIONER OF INCOME TAX BENGALURU-1 CENTRAL REVENUE BUILDING, - 66 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS NO.1, QUEENS ROAD BANGALORE - 560 001. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. MANJURAMASWAMY HANUMANTHA GOWDA S/O SRI HANUMANTHE GOWDA AGED ABOUT 69 YEARS RESIDING AT K P MAIN ROAD, THALAGATTAPURA BENGALURU - 560 060. ...RESPONDENT (BY SRI. ANNAMALAI S., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28.08.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 17726/2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 1056/2026 BETWEEN: 1. DEPUTY/ASSISTANT COMMISSIONER OF INCOME – TAX, CIRCLE 5(1)(1), BMTC BUILDING, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 2. ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE-3(1), BMTC BUILDING, NEAR KHB GAMES VILLAGE, - 67 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS KORAMANGALA, BENGALURU - 560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. NOVOZYMES SOUTH ASIA PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 PLOT NO. 32, 47-50, GENISYS BUILDING, EPIP AREA, WHITEFIELD, BANGALORE - 560 066 REPRESENTED HEREIN BY ITS HEAD CORPORATE FINANCE INDIA MR. ALOK TATER. ...RESPONDENT (BY SMT. TANMAYEE RAJKUMAR., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 06.11.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 33380/2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 1057/2026 BETWEEN: 1. INCOME TAX OFFICER WARD 1 AND TPS HASSAN, AAYAKAR BHAVAN, 2ND STAGE, BELUR ROAD, HASSAN - 573 201. - 68 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 2. PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU - 3, THE SPECIFIC AUTHORITY UNDER SECTION 151 OF THE INCOME TAX ACT, 1961 BMTC BUILDING, BMTC BHAVAN, 80 FEET ROAD, NEAR SONY WORLD SIGNAL KORAMANGALA, BENGALURU - 560 034. 3. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), A CENTRE DESCRIBED UNDER SECTION 144B OF THE INCOME TAX, 1961, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC). 4. ASSESSMENT UNIT, A UNIT CREATED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110 003, REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC) ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. HULIKERE NAGESH BHAVANTH ARADYA S/O SRI NAGESH H M, AGED ABOUT 30 YEARS, NO. 7216, NEAR NES QUARTERS, MARUTHI NAGAR, ARSIKERE TQ, HASSAN - 573 103. ...RESPONDENT (BY SRI. SREEHARI KUTSA, ADVOCATE) - 69 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28/08/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.7566/2025 AND PASS SUCH OTHER ORDER. IN WA NO. 1058/2026 BETWEEN: 1. INCOME TAX OFFICER WARD 3(2)(1), BENGALURU BMTC BUILDING, 80FT ROAD, 6TH BLOCK, KORAMANGALA, NEAR KHB GAMES VILLAGE, BENGALURU - 560 095. 2. INCOME TAX OFFICER, WARD 3(1)(3), BENGALURU BMTC BUILDING, 80FT ROAD, 6TH BLOCK, KORAMANGALA, NEAR KHB GAMES VILLAGE, BENGALURU - 560 095. 3. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA AND GOA, BENGALURU THE SPECIFIED AUTHORITY UNDER SECTION 151 OF THE INCOME TAX ACT, 1961 CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001. 4. ASSESSMENT UNIT A UNIT CREATED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961 ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC). - 70 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 5. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), A CENTRE DESCRIBED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961 ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC). 6. PRINCIPAL COMMISSIONER OF INCOME TAX/COMMISSIONER OF INCOME TAX - 6, BENGALURU, BMTC BUILDING, 80FT ROAD, 6TH BLOCK, KORAMANGALA, NEAR KHB GAMES VILLAGE, BENGALURU - 560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. POOJAMMA WIFE OF SRI. MUNIRAJU, AGED ABOUT 67 YEARS, NO. 2, GOVERNMENT SCHOOL ROAD, NEAR ESHWARA TEMPLE, OLD MYSORE ROAD, KUMBALAGOODU, BENGALURU - 560 060. ...RESPONDENT (BY SRI. SREEHARI KUTSA, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28/08/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.25201/2024 AND PASS SUCH OTHER ORDER. - 71 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS IN WA NO. 1059/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 5(1)(1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU - 3, BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 3. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BENGALURU -3 (1) BMTC BUILDING 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BANGALORE-560 095. 4. THE DEPUTY /ASSISTANT DIRECTOR OF INCEME TAX, (INV.) 2(4) C R BUILDINGS ANNEXE, NO.1 QUEENS ROAD, BANGALORE-560 001. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. M/S OZONE REALTORS PRIVATE LIMITED REPRESENTED BY ITS DIRECTOR, SRI. VASUDEVAN SATHYAMOORTHY, SON OF LATE SRI. V. SATHYAMOORTHY AGED ABOUT 57 YEARS, PRESENTLY AT NO. 35/1 - 72 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 2ND FLOOR, YELLAPPA CHETTY LAYOUT, CIVIL STATION, ULSOOR ROAD, BANGALORE - 560 042. ...RESPONDENT (BY SRI. ANNAMALAI S., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 23.10.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 16758/2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 1066/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 5 (1) (1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560095. 2. THE JOINT / ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 3(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560095. 3. THE DEPUTY / ASSISTANT DIRECTOR OF INCOME TAX, (INV.) 2(4) C R BUILDINGS ANNEXE, NO. 1, QUEENS ROAD BANGALORE – 560001. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) - 73 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS AND: 1. M/S OZONE INFRA DEVELOPERS PRIVATE LIMITED COMPANY INCORPORATED UNDER THE COMPANIES ACT 1956, REPRESENTED BY ITS DIRECTOR, SRI. S. SAI PRASAD, SON OF SRI. V. SATHYAMOORTHY, AGED ABOUT 51 YEARS, NO. 35/1, 2ND FLOOR, YELLAPPA CHETTY LAYOUT, CIVIL STATION, ULSOOR ROAD, BANGALORE - 560042. PAN AABCO2040G. ...RESPONDENT (BY SRI. ANNAMALAI S.,ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 23.10.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 21301/2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 1074/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 5(1) (1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560 095. 2. THE CHIEF COMMISSIONER OF INCOME TAX BENGALURU -1, CENTRAL REVENUE BUILDING NO.1, QUEENS ROAD, BANGALORE - 560 001. - 74 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 3. THE ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 3(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560 095. 4. THE DEPUTY/ASSISTANT DIRECTOR OF INCOME TAX, (INV.) 2(4) C R BUILDINGS ANNEXURE, NO. 1, QUEENS ROAD BANGALORE - 560 001. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. M/S OZONE INFRA DEVELOPERS PRIVATE LIMITED REPRESENTED BY ITS DIRECTOR, SRI. S. SAI PRASAD, SON OF SRI. V. SATHYAMOORTHY, AGED ABOUT 51 YEARS, NO.35/1, 2ND FLOOR, YELLAPPA CHETTY LAYOUT, CIVIL STATION, ULSOOR ROAD, BANGALORE - 560 042. ...RESPONDENT (BY SRI. ANNAMALAI S., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 23/10/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.15709/2024 AND PASS SUCH OTHER ORDER. IN WA NO. 1075/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD - 1 AND TPS, MANDYA, - 75 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS INCOME TAX OFFICER, CAUVERY PARK ROAD, MANDYA - 571 401. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3, BENGALURU, BMTC BUILDING, 70 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 3. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM 401, 2ND FLOOR, E-RAMP, JAWARLAL NEHRU STADIUM, DELHI - 110 003. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. DILEEP KUMAR KRISHNA MURTHY SON OF N KRISHNA MURTY, AGED ABOUT 51 YEARS, NO. 135/2, N M ROAD, PANDAVAPURA, MANDYA - 571 434. ...RESPONDENT (BY SRI. HEMANT VENKATRAY PAI., ADVOCATE AND SMT. LOCHANA S. BABU, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 24/09/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.23544/2024 - 76 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS AND PASS SUCH OTHER ORDER. IN WA NO. 1080/2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 3(1)(1), BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 095. 2. ADDITIONAL / JOINT COMMISSIONER OF INCOME TAX, RANGE -3(1) BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. INFOSYS BPM LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT 1956 HAVING ITS REGISTERED OFFICE AT PLOT NO. 26/3, 26/4, 26/6, HOSUR ROAD, ELECTRONIC CITY, BENGALURU - 560 100 REPRESENTED BY ITS AUTHORIZED SIGNATORY ANAND KUMAR JAISWAL. ...RESPONDENT (BY SMT. TANMAYEE RAJKUMAR., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 10.10.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 29742/2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND - 77 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 1087/2026 BETWEEN: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 5(1)(1), BMTC BUILDING, 80 FT ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA BENGALURU - 560 095. 2. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 3(1)(1) BMTC BUILDING, 80 FT ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA BENGALURU - 560 095. 3. THE ASSESSMENT UNIT INCOME TAX DEPARTMENT REP BY THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU -3 BMTC BUILDING, 80 FT ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU-560 095. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. M/S NIRPL VENTURES PRIVATE LIMITED, 7TH FLOOR, NITESH TIMESQUARE, 8, MG ROAD, BANGALORE - 560 001 REP BY ITS SPECIAL OFFICER, - 78 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS SATISH KUMAR S, AGED ABOUT 44 YEARS, S/O. SHIVASHANKARACHARI ...RESPONDENT (BY SRI. CHYTANYA K.K., SENIOR COUNSEL FOR SRI. TATA KRISHNA., ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28.08.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 11056/2025 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 1098/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 5(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560 095. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-3, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560 095. 3. THE ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 3(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560 095. 4. THE DEPUTY/ASSISTANT DIRECTOR OF INCOME TAX, (INV.) 2(4) - 79 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS C R BUILDINGS ANNEXURE, NO. 1, QUEENS ROAD BANGALORE - 560 001. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. M/S OZONE INFRA DEVELOPERS PRIVATE LIMITED REPRESENTED BY ITS DIRECTOR, SRI. S. SAI PRASAD, SON OF SRI. V. SATHYAMOORTHY, AGED ABOUT 51 YEARS, NO.35/1, 2ND FLOOR, YELLAPPA CHETTY LAYOUT, CIVIL STATION, ULSOOR ROAD, BANGALORE 560 042. ...RESPONDENT (BY SRI. ANNAMALAI S.,ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 23.10.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 11707/2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 1099/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD 1 AND TPS, HASSAN AAYAKAR BHAVAN, 2ND STAGE, BELUR ROAD, HASSAN - 573 201. - 80 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 2. THE ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT, 2ND FLOOR, JAWAHARLAL NEHRU STADIUM, NEW DELHI - 110 003. 3. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA AND GOA GROUND FLOOR, C R BUILDING, NO.1 QUEENS ROAD, BENGALURU - 560 001. 4. IDBI BANK LIMITED HASSAN BRANCH, KENCHAMBA ARCADE, SAMPIGE ROAD, HASSAN 573 201 REPRESENTED HEREIN BY ITS BRANCH MANAGER. 5. FEDERAL BANK, CHANNARAYAPATTANA BRANCH, GROUND FLOOR, MADHU COMPLEX, MYSORE ROAD, CHANNARAYAPATTANA - 573 116 REPRESENTED HEREIN BY ITS BRANCH MANAGER. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. SRI S S NAGESHA SON OF LATE SUBRAMANYA S.N. AGED ABOUT 50 YEARS AMBIKA NAGARA, 2ND CROSS, MAKAN GURUMARANAHALLI, B.M ROAD, CHANNARAYAPATTANA, HASSAN - 573 116. ...RESPONDENT (BY SRI. SANDEEP HUILGOL, ADVOCATE) - 81 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 28.08.2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP No. 35312/2024 (T-IT) AND PASS SUCH OTHER ORDER AS THIS HON’BLE COURT DEEMS FIT, UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, IN THE INTEREST OF JUSTICE AND EQUITY. IN WA NO. 1105/2026 BETWEEN: 1. DEPUTY COMMISSIONER OF INCOME TAX CC/ACIT, CIRCLE 5(1)(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU - 560 095. ...APPELLANT (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. PISCES ESERVICES PRIVATE LIMITED HAVING ITS REGISTERED OFFICE AT 413, 3RD FLOOR REGENT INSIGNIA 17TH MAIN, 100 FEET ROAD, KORAMANGALA, S O BANGALORE SOUTH, BANGALORE - 560 034 REPRESENTED BY ITS AUTHORISED SIGNATORY / MANAGING DIRECTOR MR SOUMYA M (D/O MADHAVA MURTHY). ...RESPONDENT (BY SRI. K.R. PRADEEP, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 11/11/2025 PASSED - 82 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS BY THE LEARNED SINGLE JUDGE IN WP NO.26892/2024 AND PASS SUCH OTHER ORDER. IN WA NO. 1106/2026 BETWEEN: 1. THE INCOME TAX OFFICER WARD – 3(2)(1) BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU - 560 095. 2. THE INCOME TAX OFFICER WARD-3(1)(3) BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU - 560 095. 3. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA AND GOA C.R. BUILDING, QUEEN'S ROAD BENGALURU - 560 001. 4. ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT MINISTRY OF FINANCE ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM DELHI-110 003. ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. RASHMI SHYAM WIFE OF LATE SHYAM SUNDAR - 83 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS NO.502, 1ST FLOOR, JAYANAGARA HBCS LAYOUT 1ST STAGE, VAJRAMUNI NAGAR THURAHALLI, BENGALURU - 560061. ...RESPONDENT (BY SRI. HEMANT VENKATRAY PAI, ADVOCATE AND SMT. LOCHANA S. BABU, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 24/09/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.23263/2024 AND PASS SUCHO THER ORDER. IN WA NO. 1111/2026 BETWEEN: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BENGALURU BMTC BUILDING, 80FT ROAD, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU- 560 095. 2. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU - 3, THE SPECIFIED AUTHORITY UNDER SECTION 151 OF THE INCOME TAX ACT, 1961 BMTC BUILDING 80FT ROAD, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 3. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), A CENTRE DESCRIBED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961 ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC). - 84 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 4. ASSESSMENT UNIT A UNIT CREATED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961 ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC). ...APPELLANTS (BY SRI. THIRUMALESH M, SR. STANDING COUNSEL AND SMT. ROOPA, ADVOCATE) AND: 1. SANJEEV JACOB SON OF SRI. PAUL JACOB, AGED ABOUT 58 YEARS, NO.40, 1ST MAIN, 4TH CROSS, DEFENSE COLONY, INDIRANAGAR, BENGALURU - 560 028. ...RESPONDENT (BY SRI. SHREEHARI KUTSA, ADVOCATE) THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT READ WITH ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO ALLOW THE APPEAL AND SET ASIDE THE ORDER DATED 09/10/2025 PASSED BY THE LEARNED SINGLE JUDGE IN WP NO.27942/2025 AND PASS SUCH OTHER ORDER. THESE APPEALS, COMING ON FOR FURTHER HEARING, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.G.PANDIT and HON'BLE MR. JUSTICE K. V. ARAVIND - 85 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS ORAL JUDGMENT (PER: HON'BLE MR. JUSTICE S.G.PANDIT) The above writ appeals are part of a batch of Writ Appeals filed under Section 4 of the Karnataka High Court Act, 1961 directed against the learned Single Judge’s orders allowing the writ petitions, whereunder the respondent/assessee had challenged the notice(s) issued under Sections 148/148A of the Income Tax Act, 1961 (for short, ‘the Act’) and/or reassessment order passed under Section 147 of the Act. 2. The above writ appeals are listed on the memo moved by learned counsel for the appellants/Revenue and the matter was taken up for final disposal with the consent of learned counsel appearing for the parties. 3. Learned counsel appearing for the parties bring to the notice of this Court the order passed by the Hon'ble Apex Court in Civil Appeal No.4716/2026 dated 10.04.2026 reported in [2026] 185 Taxmann.com 1007 - 86 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS (SC), whereunder the Hon'ble Apex Court in identical fact situation, taking note of the amendment by way of insertion of Section 147A into the Income Tax Act, passed the following order: “15. It is stated by the Learned Assistant Solicitor General that by inserting Section 147A into the IT Act, the term ‘Assessing Officer’ has been expressly clarified to mean an officer other than the faceless units and the same is deemed to have come into effect retrospectively from 01.04.2021. The said provision reads as follows: Insertion of new section 147A. 9. After section 147 of the Income-tax Act, the following section shall be inserted and shall be deemed to have been inserted with effect from the 1st day of April, 2021, namely:–– “147A. Notwithstanding anything contained in any judgement, order or decree of any court or in section 151A or in any scheme framed thereunder, for the removal of doubts, it is hereby clarified that the Assessing Officer for the purposes of sections 148 and 148A shall mean and shall always be deemed to have meant to be an Assessing Officer other than the National Faceless Assessment Centre or any assessment unit referred to in sub- section (3) of section 144B.”. 16. It is also asserted that the amendment to Section 279 of the Income Tax Act, 2025 is to bring it in consonance with the newly inserted Section 147A of the IT Act, thereby implying that the “Assessing Officer” for the purposes of Sections 280 and 281 of the Income Tax Act, - 87 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 2025 shall mean to be an Assessing Officer other than the NFAC or any assessment unit referred to in Section 273(3). The amended Section 279 reads as follows: 71. In section 279 of the Income-tax Act, after sub-section (2), the following sub-section shall be inserted, namely: –– ‘(3) The “Assessing Officer” for the purposes of sections 280 and 281 shall mean to be an Assessing Officer other than the National Faceless Assessment Centre or any assessment unit referred to in section 273(3).’ 17. In this backdrop, where an interpretative issue concerning the older provisions is already under consideration, it is contended on behalf of the Appellant- Revenue that the Parliament, from the outset, intended that while notices could be issued by either the JAO or the Faceless Assessing Officer (FAO), the subsequent quasi-judicial adjudication of such notices was to be undertaken by the FAOs. 18. It is urged that, in light of the divergent views taken by the High Courts owing to perceived ambiguity in the existing law, Parliament has now made the clarificatory amendment with retrospective effect from 01.04.2021, the date on which the original provisions came into force, and that the alleged anomalous situation, if any, has been removed. It was additionally submitted that the power to enact retrospective amendments is well settled in law, and that fresh notices will now be issued to assessees in accordance with the clarified position, so that pending reassessment proceedings may be concluded in accordance with law. 19. Conversely, it has been vehemently urged on behalf of the assessees that the new Amendment is not - 88 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS ‘clarificatory’ in nature but is rather an abortive attempt to fasten penal liability retrospectively, which is impermissible under law. It is their contention that the amending laws having antedated civil consequences ought to be construed strictly. 20. In all fairness, we may add that several other contentions have also been raised by both sides, which we do not consider it necessary to advert to at this stage in light of the order we propose to pass. In the facts of the present batch, we are of the considered view that it is not necessary for this Court to examine the merits of the rival submissions concerning the correctness of the impugned judgments or the scope of the competing precedents at this juncture. 21. It appears to us that the assessees would be entitled to challenge the amending provisions as elaborated upon heretofore, for which it would only be appropriate to relegate them to the jurisdictional High Courts. All contentions raised before us, as well as any other grounds available to them to question the impugned notices, may be urged before the High Courts instead. 22. Since the High Courts have primarily quashed the reassessment notices on the ground that the JAOs lacked competence to initiate such proceedings, and the very foundation of that view now stands altered by the amending legislation, the impugned judgments in favor of the assessees are set aside on this limited ground. The matters are accordingly remitted to the respective High Courts for fresh consideration. Ordered accordingly. 23. The assessees are granted liberty to amend their writ petitions, if so advised, within a period of four (4) weeks from the date of uploading of this order, so as to - 89 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS enable them to lay challenge to Section 147A of the IT Act, as introduced by Act No. 4 of 2026, or to any other connected or consequential provision. 24. Similarly, the Appellant-Revenue shall be at liberty to file their written submissions and affidavits before the jurisdictional High Courts within a period of three (3) weeks thereafter. 25. No additional time shall be granted to the parties beyond what has been granted above. 26. We make it clear that we have not expressed any opinion on the merits of the controversy, including the validity, scope, effect, retrospectivity or applicability of the amended provisions, and all such questions are left open to be decided by the High Courts. 27. Finally, during the pendency of the writ petitions before the High Courts, there shall be an interim stay of further assessment/reassessment proceedings pursuant to the impugned notices, subject to such terms and conditions as may be imposed by the High Courts. 28. The High Courts are requested to decide the matters preferably by 30.09.2026. Learned counsel for the parties undertake to extend full cooperation to the High Courts in this regard. No adjournments may be granted by the High Courts on mere asking of the parties.” 4. Learned counsel appearing for the parties seek disposal of the above writ appeals in terms of the order passed by the Hon'ble Apex Court, referred to above. - 90 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS Further, learned counsel appearing for the respondent/assessee seeks liberty to lay challenge to Section 147A of the Act in terms of the liberty granted by the Hon'ble Apex Court. 5. Learned Senior counsel Sri. K.K. Chythanya also brings to the notice of this Court, order dated 04.05.2026 in SLP(C).No.8682/2024 passed by the Hon'ble Apex Court taking note of the order dated 10.04.2026 in Civil Appeal.No.4716/2026, which reads as follows: “7. Consequently, keeping in mind the reasons set out in order dated 10.04.2026, the impugned judgment in each appeal is set aside and the instant appeals are disposed of by remitting the matters to the jurisdictional High Courts for redetermination of the issues. As observed above, the High Courts shall firstly determine whether the matters pertain to Assessment Year 2015-16. If it is found to be so, no further adjudicatory exercise shall be required to be undertaken by the High Court, except to declare the notices as being time-barred in light of Rajeev Bansal (supra). However, if it is found that the case does not pertain to Assessment Year 2015-16, then all the issues shall be resolved in terms of the order dated 10.04.2026 passed in Civil Appeal No.4716 of 2026.” - 91 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS 6. Taking note of the submissions of the learned counsel appearing for the parties as well as taking note of the above referred orders of the Hon'ble Apex Court, we do not deem it fit to go into the merits of the case. We deem it appropriate to set aside the order passed by the learned Single Judge and remit the matter to the learned Single Judge with liberty to the respondent/assessee to lay challenge to Section 147A of the Act, keeping open all the contentions of the parties, including the observations made by the Hon'ble Apex Court in order dated 04.05.2026 in SLP(C).No.8456/2025 and Connected Appeals. 7. Hence, the following: ORDER a) Writ appeals are allowed. ORDER a) Writ appeals are allowed. b) Orders passed by the learned Single Judge dated 24.09.2025 in W.P. No.32640/2024 (T-IT), dated 28.08.2025 in W.P. No.28182/2024 (T-IT), dated 08.09..2025 in W.P. No.13471/2025(T-IT), dated 24.09.2025 in W.P. No.12089/2025 (T-IT), - 92 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS dated 24.10.2025 in W.P. No.31674/2025 (T-IT), dated 04.11.2025 in W.P. No.33180/2024 (T-IT), dated 28.08.2025 in W.P. No.11194/2023 (T-IT), dated 24.09.2025 in W.P. No.7008/2025 (T-IT), dated 05.11.2025 in W.P. No.33348/2024 (T-IT), dated 13.10.2025 in W.P. No.25758/2025 (T-IT), dated 28.08.2025 in W.P. No.25404/2024 (T-IT), dated 28.08.2025 in W.P. No. 14155/2024 (T-IT), dated 24.09.2025 in W.P. No.33305/2024 (T-IT), dated 18.11.2025 in W.P. No.33872/2024 (T-IT), dated 11.11.2025 in W.P. No.17392/2024 (T-IT), dated 28.08.2025 in W.P. No.16764/2024 (T-IT), dated 04.11.2025 in W.P. No.32829/2024 (T-IT), dated 08.09.2025 in W.P. No.14686/2024 (T-IT), dated 04.09.2025 in W.P. No.23251/2025 (T-IT), dated 19.11.2025 in W.P. No.21864/2025 (T-IT), dated 18.09.2025 in W.P. No.18201/2025 (T-IT), dated 13.11.2025 in W.P. No.34103/2025 (T-IT), dated 28.08.2025 in W.P. No.20550/2022 (T-IT), dated 14.11.2025 in W.P. No.34097/2025 (T-IT), dated 29.10.2025 in W.P. No.32231/2025 (T-IT), dated 07.11.2025 in W.P. No.10103/2025 (T-IT), dated 24.09.2025 in W.P. No.33109/2024 (T-IT), dated 17.11.2025 in W.P. No.34260/2025 (T-IT), dated 28.08.2025 in W.P. No.17352/2022 (T-IT), dated 29.10.2025 in W.P. No.31047/2024 (T-IT), dated 16.10.2025 in W.P. No.28484/2025 (T-IT), dated 16.10.2025 in W.P. No.26476/2025 (T-IT), dated 10.10.2025 in W.P. No.29554/2025 (T-IT), - 93 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS dated 11.11.2025 in W.P. No.19179/2024 (T-IT), dated 13.10.2025 in W.P. No.27236/2025 (T-IT), dated 16.10.2025 in W.P. No.28502/2025 (T-IT), dated 03.12.2025 in W.P. No.36426/2025 (T-IT), dated 04.09.2025 in W.P. No.21221/2025 (T-IT), dated 28.08.2025 in W.P. No.35113/2024 (T-IT), dated 24.09.2025 in W.P. No.4377/2025 (T-IT), dated 04.09.2025 in W.P. No. 19658/2024 (T-IT), dated 28.08.2025 in W.P. No.14767/2024 (T-IT), dated 13.10.2025 in W.P. No.28823/2025 (T-IT), dated 08.09.2025 in W.P. No.18965/2024 (T-IT), dated 28.08.2025 in W.P. No.19581/2024 (T-IT), dated 24.09.2025 in W.P. No.27681/2025 (T-IT), dated 28.08.2025 in W.P. No.10890/2024 (T-IT), dated 28.08.2025 in W.P. No.17003/2024 (T-IT), dated 13.10.2025 in W.P. No.28391/2025 (T-IT), dated 13.10.2025 in W.P. No.28937/2025 (T-IT), dated 24.09.2025 in W.P. No.12788/2025 (T-IT), dated 08.09.2025 in W.P. No.23541/2024 (T-IT), dated 28.08.2025 in W.P. No.29838/2024 (T-IT), dated 04.11.2025 in W.P. No.32751/2024 (T-IT), dated 31.10.2025 in W.P. No.23131/2025 (T-IT), dated 28.08.2025 in W.P. No.17726/2024 (T-IT), dated 06.11.2025 in W.P. No.33380/2025 (T-IT), dated 28.08.2025 in W.P. No.7566/2025 (T-IT), dated 28.08.2025 in W.P. No.25201/2024 (T-IT), dated 23.10.2025 in W.P. No.16758/2024 (T-IT), dated 23.10.2025 in W.P. No.21301/2025 (T-IT), dated 23.10.2025 in W.P. No.15709/2024 (T-IT), - 94 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS dated 24.09.2025 in W.P. No.23544/2024 (T-IT), dated 10.10.2025 in W.P. No.29742/2025 (T-IT), dated 28.08.2025 in W.P. No.11056/2025 (T-IT), dated 23.10.2025 in W.P. No.11707/2024 (T-IT), dated 28.08.2025 in W.P. No.35312/2024 (T-IT), dated 11.11.2025 in W.P. No.26892/2024 (T-IT), dated 24.09.2025 in W.P. No.23263/2024 (T-IT), dated 09.10.2025 in W.P. No.27942/2025 (T-IT), are set aside. c) Liberty is granted to the respondent/assessee to lay challenge to section 147A of the Act as introduced by Act No.4 of 2026 or to any other connected or consequential provisions, within four weeks from today. d) The appellant/Revenue is granted three weeks thereafter to file additional affidavit or submission. e) Learned Single Judge is requested to take note of the timeline laid down by the Hon'ble Apex Court as extracted above. f) The interim order as granted by the Hon’ble Apex Court would enure to the benefit of the parties herein. - 95 - HC-KAR NC: 2026:KHC:24873-DB WA No. 2116 of 2025 C/W WA No. 2114 of 2025 WA No. 28 of 2026 AND 67 OTHERS Pending I.As, in this batch of appeals stand disposed of. Sd/- (S.G.PANDIT) JUDGE Sd/- (K. V. ARAVIND) JUDGE MV List No.: 1 Sl No.: 23