INNOVATIVE FILM ACADEMY PRIVATE LIMITED(OPC) vs. INCOME TAX OFFICER,

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF JULY, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 20615 OF 2026 (T-IT)

BETWEEN:

INNOVATIVE FILM ACADEMY PRIVATE LIMITED(OPC) NO.135, OUTER RING ROAD, VARTHUR HOBLI, MARTHAHALLI, BANGALORE-562109 PAN AADCI7377L ALSO AT SARAVANA PRASAD, AGED ABOUT 60 YEARS, S/O LATE TJ VENUGOPAL, NO. 22/131, F BLOCK, BDA MIG FLATS, DOMLUR 2ND STAGE, BANGALORE-560071 REGISTERED UNDER THE COMPANIES ACT.2013

…PETITIONER

(BY SRI. RAVISHANKAR S V., ADVOCATE) AND:

Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA

JAWAHARLAL NEHRU STADIUM, DELHI - 110003.

…RESPONDENTS

(BY SRI. M. THIRUMALESH, ADVOCATE)

THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO I) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE ORDER UNDER SECTION 143(3) R.W.S 144B OF THE ACT 24/03/2026, ITBA/AST/S/143(3)/2025-26/1087822212(1) ISSUED BY THE RESPONDENT NO.2 FOR THE ASSESSMENT YEAR 2024-25 HEREIN MARKED AS ANNEXURE-A. II) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE NOTICE UNDER SECTION 274 R.W.S 271AAC(1) OF THE ACT ITBA/PNL/S/271AAC(1)/2025-26/1087822295(1) THE RESPONDENT NO. 2 FOR THE ASSESSMENT YEAR 2024-25 HEREIN MARKED AS ANNEXURE-A1. III) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE NOTICE UNDER SECTION 274 R.W.S 271D OF THE ACT ITBA/PNL/S/271D/2025-26/1087822297(1) THE RESPONDENT NO. 2 FOR THE ASSESSMENT YEAR 2024-25 HEREIN MARKED AS ANNEXURE-A2. IV) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE NOTICE UNDER SECTION 274 R.W.S 271E OF THE ACT ITBA/PNL/S/271E/2025-26/1087822299(1) THE RESPONDENT NO. 2 FOR THE ASSESSMENT YEAR 2024-25 HEREIN MARKED AS ANNEXURE-A3.

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's grievance is with the Assessment Order dated 24.03.2026 [Annexure-A] under Section 143(3) read with Section 144B of the Income Tax Act, 1961. This Assessment Order is for the assessment year 2024-25. The petitioner has also called in question the Penalty Notices [as per Annexures A1 to A3] which are consequent to Annexure - A. Mr. Ravi Shankar S V, the learned counsel for the petitioner, submits that the petitioner seeks interference for restoration of the proceedings with an opportunity provide confirmation certificates as permitted in the Communication dated 16.03.2026.

Mr. Ravi Shankar S V submits that, upon receipt of this Communication which allowed only two days' time [i.e., until 18.03.2026], the petitioner bonafide attempted secure Confirmation

Certificates from third parties. The petitioner could not upload the Certificates after 18.03.2026 because the access was blocked and the impugned order is within 6 days thereafter. Mr. M. Thirumalesh, the learned Standing counsel who accepts notice for the respondents, is heard on the afore.

This Court is of the view that in the circumstances, there must be another opportunity to the petitioner to produce the relevant Confirmation Certificates so that the Assessing Officer can, as intended in the Communication dated 16.03.2026, examine those Certificates to verify whether it relates to the material already placed on record by the petitioner. Hence, the following. ORDER

[A] The petition is allowed in-part.

[B] The impugned Assessment Order dated 24.03.2026 [Annexure - A] and the Penalty Notices dated 24.03.2026

[Annexures - A1 to A3] are quashed reserving liberty to the petitioner to upload Confirmation Certificates pursuant to the Communication dated 16.03.2026 as and when enabled by the Authority consequent this Order.

Sd/- (B M SHYAM PRASAD) JUDGE