- 1 - HC-KAR NC: 2026:KHC:22739 WP No. 8828 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF APRIL, 2026 BEFORE THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV WRIT PETITION NO. 8828 OF 2026 (T-IT) BETWEEN: 1. METRICSTREAM INFOTECH (INDIA) PRIVATE LIMITED NO. 23 AND 24, AMR TECH PARK, 4B, HONGASANDRA VILLAGE, BEGUR HOBLI, BENGALURU -560 068 (REPRESENTED BY ITS DIRECTOR MR. VINOD KUMAR, S/O. MR NARASIMHAIAH, AGED ABOUT 38 YEARS) COMPANY REGISTERED UNDER COMPANIES ACT … PETITIONER (BY SMT. GEETHA RANI K., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), 2ND FLOOR, BMTC COMMERCIAL COMPLEX, 80FT ROAD, KORAMANGALA BENGALURU - 560 095 2. DEPUTY COMMISSIONER OF INCOME TAX DC/ACIT TP 2(1)(1) BMTC BUILDING, 80 FEET ROAD, Digitally signed by PRAKASH N Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:22739 WP No. 8828 of 2026 KORMANGALA BANGALORE-560 095 3. THE ADDITIONAL/JOINT/DEPUTY /ASSISTANT/COMMISSIONER OF INCOME TAX, INCOME TAX OFFICER - ASSESSMENT UNIT, NATIONAL FACELESS -ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE ROOM 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM NEW DELHI-11000 … RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) *** THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO(A) QUASH AS FAR AS THE PETITIONER IS CONCERNED BY AN APPROPRIATE WRIT OR ORDER IN THE NATURE OF CERTIORARI OR OTHERWISE THE IMPUGNED RECTIFICATION ORDER DATED 01.12.2025 ISSUED BY THE LEARNED FIRST RESPONDENT UNDER SECTION 154 VIDE DIN ITBA/REC/M/154/2025- 26/1082948939(1) FOR AY 2013-14, ENCLOSED IN ANNEXURE A AND ETC. THIS PETITION COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S SUNIL DUTT YADAV - 3 - HC-KAR NC: 2026:KHC:22739 WP No. 8828 of 2026 ORAL ORDER The petitioner has called in question the validity of the order of rectification dated 01.12.2025 passed by the respondent no.1 at Annexure-A. Petitioner has also sought for setting aside of certain allied proceedings. 2. It is the case of the petitioner that pursuant to the order passed under Section 92CA(3) of the Income Tax Act, 1961 at Annexure-F, it was clear that there was no adjustment to be made. 3. It is submitted that however subsequently certain proceedings were initiated in terms of Annexure-K and pursuant to such notice, petitioner had filed reply at Annexure-L pointing out that the order under Section 92CA(3) is a settled issue. 4. It is submitted that thereafter Annexure-A has been passed, which is an order of rectification including certain conditions which was impermissible in light of the order under Section 92CA(3) of the Act. - 4 - HC-KAR NC: 2026:KHC:22739 WP No. 8828 of 2026 5. Petitioner submits that his reply at Annexure-L to the notice of the Revenue was not taken note of. Accordingly, it is submitted that Annexure-A requires to be set aside. 6. Learned Counsel Sri.E.I.Sanmathi appearing for the respondents submits that response to Annexure-K which is found at Annexure-L would be considered by the Revenue and appropriate orders will be passed. 7. Taking note of the same, the petition is allowed. The order at Annexure-A is set aside. The matter is remitted for consideration of Annexure-L as response to Annexure-K. In light of setting aside of order at Annexure-A, consequently, Demand Notice at Annexure-B is set aside. Petitioner to appear before respondent no.1 without further notice on 25.05.2026. SD/- (S SUNIL DUTT YADAV) JUDGE NP