- 1 - HC-KAR NC: 2026:KHC:29348 WP No. 6782 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. 6782 OF 2026 (T-RES) BETWEEN: YUVARAJ ACHALCHAND SHAH (HUF) REPRESENTED BY THE KARTA, YUVARAJ ACHALCHAND SHAH, AGED ABOUT 53 YEARS, S/O ACHALCHAND, A M SHAH, NO. 556, BAZAAR STREET, BANGARPET, KOLAR- 563114. …PETITIONER (BY SRI. RAVI SHANKAR S V., ADVOCATE) AND: 1. CENTRALIZED PROCESSING CENTER INCOME TAX DEPARTMENT, BANGALORE 560100. 2. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BMTC BUILDING, KORAMANGALA BANGALORE 560095. 3. PRINCIPAL COMMISSIONER OF INCOME TAX- 2 Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:29348 WP No. 6782 of 2026 THE OFFICE OF PRINCIPAL COMMISSIONER OF INCOME TAX-2 BMTC BUILDING, KORAMANGALA, BANGALORE- 560095. …RESPONDENTS (BY SRI.ARAVIND V CHAVAN., ADVOCATE FOR R1; SRI. E.I. SANMATHI A/W SRI. NIRMAL MATHEW., ADVOCATES FOR R2 AND R3) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO I) QUASHING THE INTIMATION ORDER PASSED UNDER SECTION 143(1) OF THE ACT DATED 12/01/2022, VIDE DIN CPC/2122/A2/200002844 ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2021- 22 HEREIN MARKED AS ANNEXURE - A; II) QUASHING THE INTIMATION ORDER PASSED UNDER SECTION 143(1) OF THE ACT DATED 11/11/2022, FOR ASSESSMENT YEAR 2022-23 VIDE DIN CPC/2223/A2/304495583, ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2022- 23 HEREIN MARKED AS ANNEXURE - A1; III) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE INTIMATION ORDER PASSED UNDER SECTION 143(1) OF THE ACT DATED 06/12/2023 VIDE CPC/2324/A2/404149621 ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2023-24 HEREIN MARKED AS ANNEXURE - A2. - 3 - HC-KAR NC: 2026:KHC:29348 WP No. 6782 of 2026 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 Intimation Orders under Section 143[1] of the Income Tax Act, 1961 [for short, the 'Act'] and these intimation orders are produced as Annexures - A, A1, A2 and A3. The petitioner has also called in question the orders on its applications for rectification under Section 154 of the Act. These orders are produced as Annexures B, B1 and B2. 2. The petitioner has been refused due credit towards TDS, self-assessment Tax and advance tax for the assessment years 2021-22 to 2024-25 on the ground that its PAN has been reported for certain issues due to which credit cannot be given. In the - 4 - HC-KAR NC: 2026:KHC:29348 WP No. 6782 of 2026 notes that are part of these Intimation Orders, it is recorded that the petitioner's PAN is flagged by the Assessing Officer and therefore, the petitioner must contact the person who has affected TDS. This Court, by way of interim Orders, has permitted the petitioner to approach the second respondent observing that the petitioner, when provided with necessary information, must furnish clarification. This Court has also observed that the proceedings could be completed in the interregnum based on the clarification furnished by the petitioner. 3. Sri Ravishankar S.V., the learned counsel for the petitioner, Sri E.I. Sanmathi and Sri Arvind Chavan, the learned counsels for the Revenue, submit in categorical terms that [a] the petitioner has appeared with the second respondent [b] upon being furnished with the information for the remark as afore, the petitioner has furnished clarification [c] the jurisdictional Assessing Officer, based on such - 5 - HC-KAR NC: 2026:KHC:29348 WP No. 6782 of 2026 clarification, has permitted due credit to the petitioner towards TDS, self-assessment tax and advance tax. 4. When queried, Sri Ravishankar S.V. is categorical in stating that these redress the petitioner's grievance insofar as the impugned Intimation orders and the rejection of the request for rectification, but the learned counsel submits that this Court must pass just orders because the same remark viz., the petitioner's PAN is reported for certain issues continues to be flagged and the petitioner apprehends that there would be another cause to approach this Court once again. 5. Sri E. I. Sanmathi and Sri Aravind Chavan submit that if the petitioner files a certified copy of this Order with the jurisdictional Assessing Officer, the jurisdictional Assessing Officer will consider the circumstances in which the petitioner has now been admitted to credit of tax as stated afore - 6 - HC-KAR NC: 2026:KHC:29348 WP No. 6782 of 2026 notwithstanding the remark and any other further reason that could be and cause a report to be filed with the Centralized Processing Center [CPC – Technical/CPC- TDS] for necessary correction in the respective forms. 6. This Court is of the view that if the petitioner has been admitted to credits which were denied after offering clarification in response to the information furnished, the same must be duly considered to justify the continuance which can only be if there are subsequent circumstances. The Assessing Officer, if there are no subsequent circumstances, must necessarily file a report with the CPC – Technical/CPC-TDS for necessary rectification. In the light of the afore the following ORDER [A] The petition stands disposed of observing that the impugned Intimation Orders as also the Rectification Orders [Annexures - 7 - HC-KAR NC: 2026:KHC:29348 WP No. 6782 of 2026 A, A1, A2, A3, B, B1 and B2 are rendered infructuous reserving liberty to the petitioner to file a certified copy of this Order with the jurisdictional Assessing Officer. [B] The jurisdictional Assessing Officer, upon receipt of this Order, shall examine the circumstances in which the petitioner is admitted to credit for the relevant assessment years after this Court's interim Order and forward a report to the CPC [Technical]/ CPC [TDS] for ensuring that the remark about the petitioner's PAN number is removed if it is found to be unjustified. Sd/- (B M SHYAM PRASAD) JUDGE NV