SHARAN LALITH KUMAR JAIN vs. CENTRALIZED PROCESSING CENTER

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WP/6847/2026HC KarnatakaKAHC01014832202616 June 2026Bench: B M SHYAM PRASAD7 pages
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What did the High Court hold?

The High Court disposed of the writ petition by rendering the impugned intimations and rectification orders infructuous. The court directed that the petitioner should file a certified copy of the order with the jurisdictional Assessing Officer. Upon receipt, the Assessing Officer is to examine the circumstances under which the petitioner was admitted to credit for the relevant assessment years after the court's interim order. If the remark about the petitioner's PAN number is found to be unjustified, the Assessing Officer must forward a report to the CPC (Technical)/CPC (TDS) for its removal. The court's reasoning was that if credit was granted after clarification, the continuance of the remark should be justified by subsequent circumstances, and if not, it should be rectified.

What were the facts?

The petitioner, Sharan Lalith Kumar Jain, filed a writ petition challenging intimations under Section 143(1) of the Income Tax Act, 1961, for Assessment Years (AY) 2021-22, 2022-23, and 2023-24, as well as rectification orders. The primary issue was the refusal to grant credit for TDS, self-assessment tax, and advance tax due to the petitioner's PAN being flagged by the Assessing Officer. The petitioner was directed to contact the person who effected TDS. The High Court had previously allowed the petitioner to approach the second respondent (Deputy Commissioner of Income Tax) for clarification, with the understanding that proceedings could be completed based on the petitioner's submissions.

What were the issues?

1. Whether the impugned intimations under Section 143(1) of the Income Tax Act, 1961, and the rectification orders are liable to be quashed. Assessee's Contention: The petitioner argued that while the immediate grievance regarding the credit for TDS, self-assessment tax, and advance tax was redressed after furnishing clarifications, the underlying issue of the PAN being flagged persisted. This continued flagging created apprehension of future litigation. The petitioner sought a just order to ensure the remark is removed. Revenue's Contention: The revenue submitted that if the petitioner files a certified copy of the High Court's order with the jurisdictional Assessing Officer, the officer will consider the circumstances under which credit was granted and file a report with the Centralized Processing Center (CPC) for necessary correction, notwithstanding the remark.

Which sections of the Income-tax Act were involved?

Section 143(1),Section 154

AI-generated summary — verify with the full judgment below

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HC-KAR NC: 2026:KHC:29347 WP No. 6847 of 2026

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 16TH DAY OF JUNE, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 6847 OF 2026 (T-IT)

BETWEEN:

SHARAN LALITH KUMAR JAIN AGED ABOUT 28 YEARS, S/O LALITH KUMAR, NO. 556, LALITH KUMAR, BAZAAR STREET, BANGARPET, KOLAR-563114.

…PETITIONER (BY SRI. RAVI SHANKAR S V.,ADVOCATE)

AND:

1.

CENTRALIZED PROCESSING CENTER INCOME TAX DEPARTMENT, BANGALORE 560100.

2.

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1) BMTC BUILDING, KORAMANGALA,

Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA

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HC-KAR NC: 2026:KHC:29347 WP No. 6847 of 2026

BANGALORE 560095.

3.

PRINCIPAL COMMISSIONER OF INCOME TAX- 2 THE OFFICE OF PRINCIPAL COMMISSIONER OF INCOME TAX BMTC BUILDING, KORAMANGALA, BANGALORE- 560095.

…RESPONDENTS (BY SRI.ARAVIND V CHAVAN., ADVOCATE FOR R1; SRI. E.I. SANMATHI A/W SRI. NIRMAL MATHEW ADVOCATE FOR R3 AND R3 )

THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO I) QUASHING THE INTIMATION ORDER PASSED UNDER SECTION 143(1) OF THE ACT DATED 05/07/2022, VIDE DIN CPC/2122/A3/229640363 ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2021- 22 HEREIN MARKED AS ANNEXURE-A; II) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE INTIMATION ORDER PASSED UNDER SECTION 143(1) OF THE ACT DATED 11/11/2022, FOR ASSESSMENT YEAR 2022-23 VIDE DIN CPC/2223/A3/307614959, ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2022- 23 HEREIN MARKED AS ANNEXURE-A1; III) QUASHING THE INTIMATION ORDER PASSED UNDER SECTION 143(1) OF THE ACT DATED 06/11/2023 VIDE

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HC-KAR NC: 2026:KHC:29347 WP No. 6847 of 2026

CPC/2324/A3/393400843 ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2023-24 HEREIN MARKED AS ANNEXURE-A2.

THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD

ORAL ORDER

The petitioner has called in question Intimations under Section 143[1] of the Income Tax Act, 1961 [for short, the 'Act'] and these Intimations are produced as Annexures - A, A1, A2 and A3. The petitioner has also called in question the orders on its applications for rectification under Section 154 of the Act. These orders are produced as Annexures - B, B1, B2 and B3.

2.

The petitioner has been refused credit towards TDS, self-assessment tax and advance tax for the assessment years 2021-22 to 2024-25 on the ground that its PAN has been reported for certain

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HC-KAR NC: 2026:KHC:29347 WP No. 6847 of 2026

issues. In the notes that are part of these Intimations it is recorded that the petitioner's PAN is flagged by the Assessing Officer and therefore the petitioner must contact the person who has effected TDS. This Court, by way of interim Orders, has permitted the petitioner to approach the second respondent observing that the petitioner, when provided with necessary information by the authorities, must furnish clarification. This Court has also observed that the proceedings could be completed in the interregnum based on the clarification furnished by the petitioner.

3.

Sri Ravi Shankar S.V., the learned counsel for the petitioner, Sri E.I. Sanmathi and Sri Arvind Chavan, the learned counsels for the Revenue, submit in categorical terms that [a] the petitioner has appeared before the second respondent [b] upon being furnished with the information for the remark as afore, the petitioner has furnished clarification [c]

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HC-KAR NC: 2026:KHC:29347 WP No. 6847 of 2026

the jurisdictional Assessing Officer, based on such clarification, has permitted due credit to the petitioner towards TDS, self-assessment tax and advance tax.

4.

When queried, Sri Ravi Shankar S.V. is categorical in stating that this redresses the petitioner's grievance insofar as the impugned Intimations and the rejection of the request for rectification, but the learned counsel submits that this Court must pass just orders because the same remark viz., the petitioner's PAN is reported for certain issues continues to be flagged and the petitioner apprehends that there would be another cause to approach this Court once again.

5.

Sri E. I. Sanmathi and Sri Aravind Chavan submit that if the petitioner files a certified copy of this Order with the jurisdictional Assessing Officer, the jurisdictional Assessing Officer will consider the circumstances in which the petitioner has now been

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HC-KAR NC: 2026:KHC:29347 WP No. 6847 of 2026

admitted to credit of tax as stated afore notwithstanding the remark and any other further reason that could be and cause a report to be filed with the Centralized Processing Center [CPC – Technical/CPC- TDS] for necessary correction in the respective forms.

6.

This Court is of the view that if the petitioner has been admitted to credits which were denied after offering clarification in response to the information furnished, the same must be duly considered to justify the continuance which can only be if there are subsequent circumstances. The Assessing Officer, if there are no subsequent circumstances, must necessarily file a report with the CPC – Technical/CPC-TDS for necessary rectification. In the light of the afore the following, ORDER [A] The petition stands disposed of observing that the impugned Intimations as also the

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HC-KAR NC: 2026:KHC:29347 WP No. 6847 of 2026

Rectification Orders [Annexures - A, A1, A2, A3, B, B1, B2 and B3 are rendered infructuous reserving liberty to the petitioner to file a certified copy of this Order with the jurisdictional Assessing Officer. [B] The jurisdictional Assessing Officer, upon receipt of this Order, shall examine the circumstances in which the petitioner is admitted to credit for the relevant assessment years after this Court's interim Order and forward a report to the CPC [Technical]/ CPC [TDS] for ensuring that the remark about the petitioner's PAN number is removed if it is found to be unjustified.

Sd/- (B M SHYAM PRASAD) JUDGE

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