DIMPLE LALITH JAIN vs. CENTRALIZED PROCESSING CENTER

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WP/6853/2026HC KarnatakaKAHC01014916202616 June 2026Bench: B M SHYAM PRASAD7 pages
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What did the High Court hold?

The High Court disposed of the petition, holding that the impugned intimations and rectification orders were rendered infructuous. The Court observed that if the petitioner had been granted credits after offering clarification in response to the information furnished, this must be duly considered. The Court directed that the jurisdictional Assessing Officer, upon receipt of the order, shall examine the circumstances under which the petitioner was admitted to credit for the relevant assessment years after the Court's interim order. The Assessing Officer is to 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. The petitioner was granted liberty to file a certified copy of the order with the jurisdictional Assessing Officer.

What were the facts?

The petitioner, Dimple Lalith Jain, filed a writ petition challenging intimations under Section 143(1) of the Income Tax Act, 1961, for Assessment Years 2020-21 to 2024-25, and subsequent rectification orders. The grievance was the refusal of credit for TDS, self-assessment tax, and advance tax due to the petitioner's PAN being flagged for certain issues. The intimations stated that the petitioner's PAN was flagged by the Assessing Officer, requiring contact with the deductor of TDS. The High Court had previously granted interim orders allowing the petitioner to approach the second respondent (Deputy Commissioner of Income Tax) and furnish clarifications.

What were the issues?

1. Whether the impugned intimations under Section 143(1) and the rectification orders are liable to be quashed, and if the petitioner is entitled to credit for TDS, self-assessment tax, and advance tax for Assessment Years 2020-21 to 2024-25? (Mixed question of law and fact, concerning Section 143(1) and Section 154 of the Income Tax Act, 1961). Assessee's Contention: The petitioner sought to quash the intimations and rectification orders, arguing that the continued flagging of their PAN, despite clarifications, would lead to future litigation. They sought a just order to resolve the issue permanently. Revenue's Contention: The revenue submitted that the petitioner had appeared before the second respondent, furnished clarifications, and based on these, the jurisdictional Assessing Officer had permitted due credit for TDS, self-assessment tax, and advance tax. They further stated that if the petitioner files a certified copy of the order, the Assessing Officer would consider the circumstances and file a report with the Centralized Processing Center (CPC) for necessary correction.

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:29349 WP No. 6853 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. 6853 OF 2026 (T-IT)

BETWEEN:

DIMPLE LALITH JAIN AGED ABOUT 50 YEARS, W/O LALITH JAIN, AM SHAH, NO. 556, 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 BANGALORE 560095.

3.

PRINCIPAL COMMISSIONER OF INCOME TAX- 2 THE OFFICE OF PRINCIPAL COMMISSIONER OF INCOME TAX

Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA

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HC-KAR NC: 2026:KHC:29349 WP No. 6853 of 2026

BMTC BUILDING, KORAMANGALA, BANGALORE- 560095

…RESPONDENTS (BY SRI.ARAVIND V CHAVAN., ADVOCATE FOR R1; SRI. E.I. SANMATHI A/W SRI. NIRMAL MATHEW., ADVOCATES FOR R2 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 03/03/2021, VIDE DIN CPC/2021/A2/141821145 ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2020- 21 HEREIN MARKED AS ANNEXURE-A; II) QUASHING THE INTIMATION ORDER PASSED UNDER SECTION 143(1) OF THE ACT DATED 16/02/2022, VIDE DIN CPC/2122/A2/212042508 ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2021- 22 HEREIN MARKED AS ANNEXURE-A1; III) QUASHING THE INTIMATION ORDER PASSED UNDER SECTION 143(1) OF THE ACT DATED 20/09/2022, FOR ASSESSMENT YEAR 2022-23 VIDE DIN CPC/2223/A2/296651342, ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2022- 23 HEREIN MARKED AS ANNEXURE-A2.

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

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HC-KAR NC: 2026:KHC:29349 WP No. 6853 of 2026

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, A3 and A4. 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 and B2.

2.

The petitioner has been refused credit towards TDS, self-assessment tax and advance tax for the assessment years 2020-21 to 2024-25 on the ground that its PAN has been reported for certain 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 *Retyped and Replaced vide Chamber order dated 09.09.2026.

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HC-KAR NC: 2026:KHC:29349 WP No. 6853 of 2026

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

*Retyped and Replaced vide Chamber order dated 09.09.2026.

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HC-KAR NC: 2026:KHC:29349 WP No. 6853 of 2026

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 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– *Retyped and Replaced vide Chamber order dated 09.09.2026.

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HC-KAR NC: 2026:KHC:29349 WP No. 6853 of 2026

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 Rectification Orders [Annexures A, A1, A2, A3, A4, B, B1 and B2 are rendered infructuous reserving liberty to the petitioner to file a certified copy of this *Retyped and Replaced vide Chamber order dated 09.09.2026.

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HC-KAR NC: 2026:KHC:29349 WP No. 6853 of 2026

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

NV List No.: 1 Sl No.: 39 *Retyped and Replaced vide Chamber order dated 09.09.2026.

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