- 1 - HC-KAR NC: 2026:KHC:29256 WP No. 14356 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 16TH DAY OF JUNE, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 14356 OF 2026 (T-IT) BETWEEN: DOVER INDIA PRIVATE LIMITED 1ST FLOOR BAGMANE LAUREL COMPANY INCORPORATED UNDER THE COMPANIES ACT 1956 HAVING ITS OFFICE AT 1ST FLOOR BLOCK C BAGMANE TECH PARK 560093, KARNATAKA WHOLE TIME DIRECTOR C V RAMAN NAGAR, BANGALORE - 560 093 REPRESENTED HEREIN BY ITS MR. PRASHANTH SANTHANAM …PETITIONER (BY MS. MANASA ANANTHAN., ADVOCATE FOR MS. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. ASSESSMENT UNIT., INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110003 Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:29256 WP No. 14356 of 2026 2. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(2)(1), BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU 560 095. 3. PRINCIPAL COMMISSIONER OF INCOME TAX - 1 BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU 560 095. …RESPONDENTS (BY SRI.M. DILIP., ADVOCATE A/W SRI. VINAYAKA S PANDIT., ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE ASSESSMENT ORDER DATED 24.03.2026 (ANNEXURE G) BEARING DIN ITBA/AST/S/143(3)/2025- 26/1087840730(1) PASSED BY THE 1ST RESPONDENT UNDER SECTION 143(3) READ WITH 144(B) OF THE ACT FOR THE ASSESSMENT YEAR 2024-25; (B) QUASHING THE DEMAND NOTICE DATED 24.03.2026 (ANNEXURE- H) BEARING DIN ITBA/AST/S/156/2025- 26/1087840780(1) ISSUED BY THE 1ST RESPONDENT UNDER SECTION 156 OF THE ACT FOR THE - 3 - HC-KAR NC: 2026:KHC:29256 WP No. 14356 of 2026 ASSESSMENT YEAR 2024-25; (C) QUASHING THE PENALTY NOTICE DATED 24.03.2026 (ANNEXURE -J) BEARING DIN ITBA/PNL/S/270A/2025- 26/1087840807(1) ISSUED UNDER SECTION 274 READ WITH SECTION 270A OF THE ACT FOR THE ASSESSMENT YEAR 2024-25 AND ISSUED BY R1. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD ORAL ORDER The petitioner has called in question the Assessment Order dated 24.03.2026 under Section 143[3] and 144B of the Income Tax Act, 1961 [for short, ‘the Act’] [Annexure-G] while also calling in question the Demand [Annexure-H] and the Penalty Notices [Annexure-J] of the even date. Ms. Manasa Ananthan, the learned counsel for the petitioner, submits that notwithstanding certain grounds urged, - 4 - HC-KAR NC: 2026:KHC:29256 WP No. 14356 of 2026 the petitioner would request for disposal of the petition with liberty to treat the impugned Assessment Order dated 24.03.2026 as a Show Cause Notice and opportunity to file the response to the additions made therein. In elaboration, the learned counsel submits that this request is made on behalf of the petitioner in the light of the following two grounds: [a] the petitioner has requested for an opportunity of hearing on video which is not extended [b] the Show Cause Notices were issued for different additions and the assessment proceedings are concluded accepting the cause shown against additions except for one addition and another addition which is not a part of the Show Cause Notice. Sri M Dilip and Sri Vinayaka S Pandit, the learned standing counsels for the respondents who accept notice for the respondents, are heard for final - 5 - HC-KAR NC: 2026:KHC:29256 WP No. 14356 of 2026 disposal of the petition in the light of these circumstances and the request. This Court must opine that these reasons suffice for this Court to conclude that there must be an opportunity to the petitioner to show cause against the additions made treating the impugned Assessment Order as the Show Cause Notice. In the light of the afore, the following: ORDER [a] The petition is allowed in part reading the Assessment Order dated 24.03.2026 [Annexure-G] as another Show Cause Notice with liberty to the petitioner to file response within four [4] weeks from today. Consequently, the impugned Demand and the Penalty notices [Annexures H and J] are quashed. [b] It is needless to observe that all questions on the subject are left open to be considered with the petitioner being - 6 - HC-KAR NC: 2026:KHC:29256 WP No. 14356 of 2026 extended an opportunity of video hearing if that request is part of the Reply. Sd/- (B M SHYAM PRASAD) JUDGE AN/-