M/S CLASSIC FEATHERLITE WATERFRONT DEVELOPERS LLP vs. ASSESSMENT UNIT.,

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WP/15921/2026HC KarnatakaKAHC01032666202601 June 2026Bench: B M SHYAM PRASAD5 pages
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What did the High Court hold?

The High Court allowed the writ petition in part. The Court held that the assessment proceedings were completed with the aid of Section 144B of the IT Act without communication of a decision on the request for adjournment. This, in the Court's view, was sufficient ground for interference to ensure that the proceedings were conducted after a reasonable opportunity. Consequently, the impugned assessment order, demand notice, and penalty notice (Annexures G1 to G3) were quashed. The proceedings were restored for reconsideration, with liberty granted to the petitioner to file their reply and upload documents on the portal. The authorities were directed to ensure necessary enablement on the portal upon receipt of a certified copy of the order and to communicate such enablement to the petitioner.

What were the facts?

The petitioner, M/s Classic Featherlite Waterfront Developers LLP, filed a writ petition before the High Court of Karnataka challenging an assessment order dated March 18, 2026, passed by the Assessment Unit, Income-Tax Department under Section 143(3) read with Section 144B of the Income Tax Act, 1961, for Assessment Year 2024-25. The petitioner also challenged the demand notice and penalty notice issued on the same date. The core of the petitioner's grievance was that their request for a 10-day extension of time, made on March 10, 2026, was not considered by the first respondent before passing the assessment order. The petitioner contended that they had not filed a response due to the bonafide belief that their adjournment request would be granted.

What were the issues?

1. Whether the assessment order dated March 18, 2026, passed under Section 143(3) read with Section 144B of the Income Tax Act, 1961, for Assessment Year 2024-25, is vitiated by a lack of reasonable opportunity to the assessee? Assessee's Contention: The petitioner argued that a request for a 10-day adjournment made on March 10, 2026, was not considered by the assessing authority. The petitioner further submitted that they did not file a response under the bonafide belief that their adjournment request would be acceded to. Therefore, the assessment order was passed without providing a reasonable opportunity. Revenue's Contention: The judgment records that the learned standing counsel for the respondents was heard in light of the circumstances and the narrow canvas presented. No specific arguments were recorded for the revenue regarding the merits of the adjournment request or the opportunity provided.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144B,Section 156,Section 270A,Section 274

AI-generated summary — verify with the full judgment below

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HC-KAR NC: 2026:KHC:25484 WP No. 15921 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 1ST DAY OF JUNE, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 15921 OF 2026 (T-IT) BETWEEN:

M/S CLASSIC FEATHERLITE WATERFRONT DEVELOPERS LLP DEVELOPERS LLP A LIMITED LIABILITY PARTNERSHIP REGISTERED UNDER THE LIMITED LIABILITY PARTNERSHIP ACT, 2008 HAVING OFFICE AT 678, CLASSIC HOUSE, 6TH A CROSS, 17TH MAIN, 3RD BLOCK, KORAMANGALA, BANGALORE - 560034. …PETITIONER (BY MS. MANASA ANANTHAN., ADVOCATE FOR SMT. 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

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HC-KAR NC: 2026:KHC:25484 WP No. 15921 of 2026 2. INCOME-TAX OFFICER, WARD 1(2)(1) BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE 560 095. 3. PRINCIPAL COMMISSIONER OF INCOME-TAX - 1, 5TH FLOOR, BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA BANGALORE 560095. …RESPONDENTS (BY SRI.Y.V. RAVIRAJ AND SRI VINAYAKA G PANDIT, , ADVOCATES)

THIS WP IS FILED UNDER ARTICLES 226 OF THE CONSTITUTION OF INDIA PRAYING TO (A) QUASHING THE ORDER DATED 18.03.2026 BEARING DIN ITBA/ AST/S/ 143(3)/ 2025-26/1087551060(1) (ANNEXURE- G-1) PASSED BY THE 1 RESPONDENT UNDER SECTION 143(3) READ WITH SECTION 1448 OF THE ACT, FOR THE ASSESSMENT YEAR 2024-25; (B) QUASHING THE DEMAND NOTICE DATED 18.03.2026 BEARING DIN ITBA/AST/S/156/2025-26/1087551298(1) ISSUED BY THE 1 RESPONDENT (ANNEXURE 'G-2') TO THE PETITIONER UNDER SECTION 156 OF THE ACT FOR THE ASSESSMENT YEAR 2024-25; (C) QUASHING THE PENALTY NOTICE DATED 18.03.2026 BEARING DIN ITBA/PNL/S/270A/2025-26/1087553425(1) ISSUED BY THE 1ST RESPONDENT (ANNEXURE - G-3) UNDER

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HC-KAR NC: 2026:KHC:25484 WP No. 15921 of 2026 SECTION 274 READ WITH SECTION 270A OF THE ACT FOR THE ASSESSMENT YEAR 2024- 25.

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 short question for consideration is whether this Court must intervene with the assessment order relevant to the petitioner and the assessment year 2024-25, and this question is presented with the petitioner calling in question the assessment order dated 18.03.2026 [Annexure-G1] under Section 143(3) read with Section 144B of the Income Tax Act, 1961 [for short, 'the IT Act']. The petitioner has also called in question the demand/penalty notices [Annexures - G2 and G3].

Ms. Manasa Ananthan, the learned counsel for the petitioner, submits that the short ground urged is about the lack of a reasonable opportunity, and in elaboration, the learned counsel submits that the petitioner made a request on 10.03.2026 for extension of time [for

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HC-KAR NC: 2026:KHC:25484 WP No. 15921 of 2026 adjournment by 10 days] and that the first respondent has completed the assessment proceedings by the impugned order without considering the request. The learned counsel submits that this Court may consider that the petitioner has not filed any response under the bonafide belief that the request for adjournment would be considered.

Mr. Vinayaka G. Pandit, the learned standing counsel for the respondents, is heard in the light of the circumstances and the narrow canvas presented for consideration. This Court finds that the proceedings are completed with the aid of Section 144B of the IT Act without communication of a decision on the request for adjournment and this must suffice for this Court's interference to ensure that the proceedings are after a reasonable opportunity. Hence, the following: ORDER

The petition is allowed-in-part quashing the impugned order and notices [Annexures - G1 to G3] restoring the proceedings for reconsideration with liberty to the petitioner to file reply and upload documents on the portal calling upon the authorities to ensure that there is

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HC-KAR NC: 2026:KHC:25484 WP No. 15921 of 2026 necessary enablement in this regard on the portal upon receipt of a certified copy of this order and that there is due communication of such enablement to the petitioner. Sd/- (B M SHYAM PRASAD) JUDGE SA ct:sr

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