C N COFFEE TRADING CO vs. ASSISTANT COMMISSIONER OF INCOME TAX

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WP/16632/2026HC KarnatakaKAHC01037185202605 October 2026Bench: B M SHYAM PRASAD3 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court accepted a memo filed by the learned counsel for the petitioner seeking to withdraw the writ petition. The memo stated that the petitioner most humbly sought leave to withdraw the petition and prayed for its dismissal as withdrawn. The Court noted that the memo was accepted. Consequently, the writ petition was dismissed as withdrawn. No decision was made on the merits of the issues raised by the petitioner regarding the validity of the notices and directions issued under Sections 142(2A) and 148 of the Income Tax Act, 1961. The operative direction was solely to dismiss the petition as withdrawn.

What were the facts?

The petitioner, C N Coffee Trading Co., a firm, filed a writ petition before the High Court of Karnataka challenging several actions by the Income Tax Department for Assessment Year 2023-24. The actions under challenge included a direction dated March 26, 2026, issued by the Assistant Commissioner of Income Tax under Section 142(2A) of the Income Tax Act, 1961. Also challenged were a sanction dated March 24, 2025, accorded by the Principal Commissioner of Income Tax (Central) under Section 142(2A), and a notice dated March 28, 2025, issued by the Assistant Commissioner of Income Tax under Section 148 of the Act. The petitioner sought to quash these orders and declare the proceedings initiated under Section 148 as null and void.

What were the issues?

The High Court was asked to decide the following questions, framed as prayers by the petitioner: 1. Whether the direction dated 26.03.2026 issued by the 1st respondent under Section 142(2A) of the Act for the Assessment Year 2023-24 is liable to be quashed? 2. Whether the sanction dated 24.03.2025 accorded by the 2nd respondent under Section 142(2A) of the Act for the Assessment Year 2023-24 is liable to be quashed? 3. Whether the notice dated 28.03.2025 issued by the 1st respondent under Section 148 of the Act for the Assessment Year 2023-24 is liable to be quashed? 4. Whether the proceedings initiated under Section 148 of the Act are liable to be declared null and void, and no further proceedings can be undertaken pursuant to the notice dated 28.03.2025? The petitioner's contentions were that these actions were invalid and sought their quashing. The judgment does not record any specific arguments made by the revenue.

Which sections of the Income-tax Act were involved?

Section 142(2A),Section 148

AI-generated summary — verify with the full judgment below

HC-KAR IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 5TH DAY OF OCTOBER, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 16632 OF 2026 (T-IT)

BETWEEN:

C N COFFEE TRADING CO A FIRM INCORPORATED UNDER THE INDIAN PARTNERSHIP ACT, 1932 HAVING OFFICE AT SHARIEFF STREET, NEAR MADINA MASJID ROAD, CHIKMAGALUR - 577 101 REPRESENTED HEREIN BY ITS MANAGING PARTNER MR. C.N. AKMAL. …PETITIONER (BY MS. TANMAYEE RAJKUMAR.,ADVOCATE) AND:

1.

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, HASSAN AYAKAR BHAVAN, 2ND STAGE, BELUR ROAD, HASSAN KARNATAKA - 573 201.

2.

PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), PANAJI GROUND FLOOR, PUNDAIK NIWAS, RUA-DE-OUREM,

Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA HC-KAR PATTO, PANAJI, GOA - 403 001. …RESPONDENTS (BY SRI.ARAVIND V CHAVAN., ADVOCATE)

THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO (A) QUASHING THE DIRECTIONS DATED 26.03.2026 (ANNEXURE M) BEARING NO. ITBA/AST/F/75/2025-26/1087946505(1) ISSUED BY THE 1ST RESPONDENT UNDER SECTION 142(2A) OF THE ACT, FOR THE ASSESSMENT YEAR 2023-24; (B) QUASHING THE SANCTION DATED 24.03.2025 (ANNEXURE L) BEARING NO. ITBA/COM/M/17/2025-26/1087843656(1) ACCORDED BY THE 2ND RESPONDENT UNDER SECTION 142(2A) OF THE ACT FOR THE ASSESSMENT YEAR 2023-24; (C) QUASHING THE NOTICE DATED 28.03.2025 (ANNEXURE A) BEARING NO. ITBA/AST/S/148/2024- 25/1075198436(1) ISSUED BY THE 1ST RESPONDENT UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2023-24; (D) DECLARING THAT THE PROCEEDINGS INITIATED UNDER SECTION 148 OF THE ACT AS NULL AND VOID AND THAT NO FURTHER PROCEEDINGS PURSUANT TO THE NOTICE DATED 28.03.2025 ANNEXURE-A CAN BE UNDERTAKEN.

THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN 'B' GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

HC-KAR CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD

ORAL ORDER

The learned counsel for the petitioner has filed a memo for withdrawal which reads as under:

“The petitioner most humbly seeks leave of this Hon’ble Court to withdraw the above petition.

Wherefore, it is most humbly prayed that this Hon’ble Court may be pleased to take the present memo on record and dismiss the above petition as withdrawn, in the interest of justice and equity.”

The memo is accepted, and the writ petition stands dismissed as withdrawn.

Sd/- (B M SHYAM PRASAD) JUDGE

AN/-

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