- 1 - HC-KAR CNR: KAHC010369292026 NC: 2026:KHC:36483-DB WA No. 1513 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 16TH DAY OF JULY, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE DR. JUSTICE K.MANMADHA RAO WRIT APPEAL NO. 1513 OF 2026 (T-IT) BETWEEN: 1. THE GOVERNMENT OF INDIA, REP. BY ITS SECRETARY, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NORTH BLOCK, NEW DELHI-110 001. 2. CENTRAL BOARD OF DIRECT TAXES (CBDT), REP. BY ITS CHAIRPERSON, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI-110 001. 3. PR. COMMISSIONER OF INCOME TAX, BMTC BUILDING, KORAMANGALA, BENGALURU-560 095. …APPELLANTS (BY SRI. RAVI RAJ Y. V., ADV.) AND: SMT. PUDUR ZAHEDA BEGUM WIFE OF SRI. MOHAMMED SHAFEE V.L., AGED ABOUT 63 YEARS, RESIDING AT NO.16, AM ROAD, SULTAN NAGAR, SHIVAJINAGAR, BENGALURU-560 051. …RESPONDENT Digitally signed by NANJUNDACHARI Location: High Court of Karnataka - 2 - HC-KAR CNR: KAHC010369292026 NC: 2026:KHC:36483-DB WA No. 1513 of 2026 THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT PRAYING TO A) SET ASIDE THE ORDER PASSED BY THE LEARNED SINGLE JUDGE IN W.P.NO.4688/2026 (T-IT) DATED 24.02.2026 AND B) PASS SUCH OTHER SUITABLE ORDERS AS THIS COURT DEEMS FIT ON THE FACTS AND CIRCUMSTANCES OF THE CASE AND ETC. THIS APPEAL, COMING ON FOR ORDERS, THIS DAY, JUDGMENT WAS DELIVERED THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.G.PANDIT AND HON'BLE DR. JUSTICE K.MANMADHA RAO ORAL JUDGMENT (PER: HON'BLE MR. JUSTICE S.G.PANDIT) Heard learned counsel Sri.Ravi Raj.Y.V., along with Sri.M.Dilip, learned counsel for appellants/Revenue and perused the writ appeal papers. 2. The present writ appeal is presented under Section 4 of the Karnataka High Court Act, 1961 questioning order dated 24.02.2026 in W.P.No.4688/2026, wherein the learned Single Judge on setting aside Annexure-A, order dated 12.12.2025, condoned the delay in filing the return of income for the AY 2020-21 with a direction to re-consider the same. - 3 - HC-KAR CNR: KAHC010369292026 NC: 2026:KHC:36483-DB WA No. 1513 of 2026 3. The respondent herein had filed Application under Section 119(2)(b) of the Income Tax Act, 1961 seeking condonation of delay in filing the return for AY 2020-21 for claiming refund of Rs.20,69,617/-, arising out of TDS credit on compensation received for land acquired by the KIADB. 4. This Court in W.A.NO.890/2022 DATED 27.09.2023 (BANGALORE METRO RAIL CORPORATION LIMITED VS. M/S. SRI.BALAJI CORPORATE SERVICES AND OTHERS) held that it is not required to pay income tax on compensation received and further held that the assesses are entitled for refund. Following the said judgment, learned Single Judge remanded the matter back to the Assessing Authority for re-consideration. Learned Single Judge under impugned order has observed that the Assessing Authority instead of first considering the application for condonation of delay has proceeded on merit and passed order rejection of application. - 4 - HC-KAR CNR: KAHC010369292026 NC: 2026:KHC:36483-DB WA No. 1513 of 2026 5. We do not find any good reason to disagree with the reasoning of the learned Single Judge. There is no merit in the writ appeal and accordingly, writ appeal stands rejected. Consequently, I.A.No.1/2026 for condonation of delay is also rejected. Sd/- (S.G.PANDIT) JUDGE Sd/- (DR.K.MANMADHA RAO) JUDGE NC CT:bms List No.: 1 Sl No.: 22