MPHASIS LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

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WP/24925/2024HC KarnatakaKAHC01052327202417 October 2025Bench: S.R.KRISHNA KUMAR4 pages
AI SummaryRemanded

What did the High Court hold?

The High Court of Karnataka, in its order dated October 17, 2025, directed the respondents to address the grievances of the petitioner and consider its rectification application dated March 7, 2024. The Court ordered the respondents to pass appropriate orders, bearing in mind the material on record produced by the petitioner and in accordance with law, within a period of six weeks from the date of receipt of a copy of the order. The Court did not make any specific findings on the merits of the rectification application or the claim for refund of excess DDT, as the primary prayer was for a direction to dispose of the pending application. The petition was disposed of with these directions.

What were the facts?

The petitioner, Mphasis Limited, filed a writ petition before the High Court of Karnataka seeking a direction to the Deputy Commissioner of Income Tax (R1) to dispose of its rectification application dated March 7, 2024. The petitioner also sought a direction for the refund of excess Dividend Distribution Tax (DDT) amounting to Rs. 41.56 Crores, along with interest, as per Section 244A of the Income Tax Act. The petitioner's grievance was that the rectification application had not been considered by the respondents. The respondents, through their counsel, submitted that they would consider and pass necessary orders on the application if reasonable time was granted. The High Court heard both parties and perused the material on record.

What were the issues?

1. Whether the petitioner is entitled to a writ of mandamus directing the Deputy Commissioner of Income Tax (R1) to dispose of its rectification application dated March 7, 2024, at the earliest, as per the provisions of the Income Tax Act? 2. Whether the petitioner is entitled to a writ of mandamus directing the respondents to issue a refund of excess Dividend Distribution Tax (DDT) of Rs. 41.56 Crores, along with interest, as per Section 244A of the Income Tax Act? Assessee's Contentions: The petitioner contended that its rectification application dated March 7, 2024, submitted to the respondents, had not been considered, and no order had been passed thereon. The petitioner sought a direction for the earliest disposal of this application and for the refund of excess DDT paid. Revenue's Contentions: The respondents submitted that if reasonable time were given, they would consider and pass necessary orders on the petitioner's application.

Which sections of the Income-tax Act were involved?

Section 244A

AI-generated summary — verify with the full judgment below

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HC-KAR NC: 2025:KHC:41590 WP No. 24925 of 2024

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 17TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO.24925 OF 2024 (T-IT) BETWEEN:

MPHASIS LIMITED 1ST FLOOR WTC, 3RD BLOCK B, BAGMANE WORLD TECHNOLOGY CENTRE, K R PURAM, MARATHAHLLI, OUTER RING ROAD, DOODENEKUNDI, BENGALURU – 560 048 . PAN NO.AAACB6820C A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 AND REPRESENTED BY ITS AUTHORIZED SIGNATORY MR ARIJIT GANGULY S/O AMITAVA GANGULY AGED ABOUT 52 YEARS OCCUPATION: SENIOR VICE PRESIDENT AND GROUP HEAD TAXATION RESIDING AT BAGAMANE TECHNOLOGY PARK, LAUREL BUILDING, C V RAMAN NAGAR BENGALURU – 560 003. …PETITIONER

(BY SRI. ANKUR PAI DHUNGAT, ADVOCATE)

AND:

1.

THE DEPUTY COMMISSIONER OF INCOME TAX

CIRCLE 4 (1) (1), ROOM NO.230,

2ND FLOOR, BMTC BUILDING,

80 FEET ROAD, KORAMANGALA

BENGALURU – 560 095.

2.

ASSESSMENT UNIT / INCOME TAX OFFICER

INCOME TAX DEPARTMENT,

Digitally signed by CHANDANA B M Location: High Court of Karnataka

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HC-KAR NC: 2025:KHC:41590 WP No. 24925 of 2024

MINISTRY OF FINANCE,

GOVERNMENT OF INDIA,

NORTH BLOCK,

NEW DELHI – 110 001.

3.

THE PRINCIPAL COMMISSIONER OF INCOME TAX

BMTC BUILDING, 80 FEET ROAD,

KORAMANGALA

BENGALURU – 560 095.

4.

THE CHIEF COMMISSIONER OF INCOME TAX BENGALURU - 1

CR BUILDING, QUEENS ROAD,

BENGALURU – 560 001. …RESPONDENTS (BY SRI.SUSHAL TIWARI, ADVOCATE)

THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ORDER OR DIRECTION TO R1 TO DISPOSE OF THE RECTIFICATION APPLICATION DATED 07/03/2024 (ANNX-J) AT THE EARLIEST.

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

CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR

ORAL ORDER In this petition, petitioner has sought for the following reliefs:

“(i). Issue a writ of mandamus or any other writ, order or direction to the respondent No.1 to dispose of the rectification application dated 07.03.2024 (Annexure-‘J’) at the earliest;

(ii). Issue a writ of mandamus or any other writ, order or direction to the Respondents to issue the refund of excess DDT paid of Rs.41.56 Crores to the petitioner along with interest from the date of determination of refund till the

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HC-KAR NC: 2025:KHC:41590 WP No. 24925 of 2024

date of actual refund, as per the provisions of Section 244A of the IT Act;

(iii). Issue any other writ, order or direction to which the petitioner is found entitled to in the present facts and circumstances.”

2.

Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record.

3.

It is the grievance of the petitioner that its rectification application dated 07.03.2024 at Annexure – J submitted to the respondents has not been considered so far by the respondents nor any order has been passed on the same. Under these circumstances, the petitioner is before this Court by way of the present petition. 4. Per contra, learned counsel for the respondents submits that if reasonable time is given, the respondents would consider and pass necessary order on the said application. 5. In view of the aforesaid facts and circumstances and rival submissions, the respondents are hereby directed to address the grievances of the petitioner and consider his rectification application dated 07.03.2024 at Annexure – A and pass

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HC-KAR NC: 2025:KHC:41590 WP No. 24925 of 2024

appropriate orders bearing in mind the material on record produced by the petitioner and in accordance with law, within a period of six weeks from the date of receipt of a copy of this order. 6. With the aforesaid directions, the petition stands disposed of.

Sd/- (S.R.KRISHNA KUMAR) JUDGE

SV List No.: 2 Sl No.: 1

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