LALIT KUMAR ACHALCHAND SHAH (HUF) vs. CENTRALIZED PROCESSING CENTER

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WP/6955/2026HC KarnatakaKAHC01014827202616 June 2026Bench: B M SHYAM PRASAD8 pages
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What did the High Court hold?

The High Court disposed of the petition by observing that the impugned intimations under Section 143(1) and the rectification orders have been rendered infructuous. The court reserved liberty for the petitioner to file a certified copy of the order with the jurisdictional Assessing Officer. The jurisdictional Assessing Officer, upon receiving the order, is directed to 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 further directed to forward a report to the CPC (Technical)/CPC-TDS to ensure the removal of the remark concerning the petitioner's PAN number if it is found to be unjustified. The court's reasoning was that if credit has been granted after clarification, the continuance of the remark should be justified by subsequent circumstances, and if not, a report for rectification is necessary.

What were the facts?

The petitioner, Lalit Kumar Achalchand Shah (HUF), filed a writ petition before the High Court of Karnataka challenging intimations under Section 143(1) of the Income Tax Act, 1961, for assessment years 2020-21 to 2023-24. The petitioner also challenged orders on its applications for rectification under Section 154. The grievance was the refusal of credit for TDS, self-assessment tax, and advance tax due to the petitioner's PAN being flagged by the Assessing Officer. The court had previously granted interim orders allowing the petitioner to approach the second respondent (Deputy Commissioner of Income Tax) for clarification, which was to be furnished to the authorities. The revenue confirmed that the petitioner had appeared, furnished clarification, and the jurisdictional Assessing Officer had permitted the due credit.

What were the issues?

1. Whether the impugned intimations under Section 143(1) of the Income Tax Act, 1961, and the subsequent rectification orders are liable to be quashed. Assessee's contention: The petitioner argued that while the grievance regarding the denial of credit for TDS, self-assessment tax, and advance tax for the impugned assessment years has been redressed, the underlying remark flagging the petitioner's PAN for certain issues persists. The petitioner apprehends future issues and seeks a just order to prevent recurrence. Revenue's contention: The revenue submitted that the petitioner had appeared before the second respondent, furnished clarification, and based on this, the jurisdictional Assessing Officer permitted the due credit. They further submitted that if the petitioner files a certified copy of the High Court's order, the jurisdictional Assessing Officer will 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:29345 WP No. 6955 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. 6955 OF 2026 (T-IT)

BETWEEN:

LALIT KUMAR ACHALCHAND SHAH (HUF) REPRESENTED BY THE KARTA, LALIT KUMAR ACHALCHAND SHAH, AGED ABOUT 55 YEARS, S/O ACHALCHAND, 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. REPRESENTED BY ASST. DIRECTOR OF INCOME TAX.

Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA

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HC-KAR NC: 2026:KHC:29345 WP No. 6955 of 2026

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 R2 AND R3)

THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO 1) 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 03/03/2021, VIDE DIN CPC/2021/A2/141750280 ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2020- 21 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 19/01/2022, VIDE DIN CPC/2122/A2/200004149 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 16/02/2023, FOR ASSESSMENT YEAR 2022-23 VIDE DIN

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HC-KAR NC: 2026:KHC:29345 WP No. 6955 of 2026

CPC/2223/A2/296468672, ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2022- 23 HEREIN MARKED AS ANNEXURE - A2; IV) QUASHING THE INTIMATION ORDER PASSED UNDER SECTION 143(1) OF THE ACT DATED 06/11/2023 VIDE CPC/2324/A2/351303041 ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2023.24 HEREIN MARKED AS ANNX-A3.

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 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. *Retyped and Replaced vide Chamber order dated 09.09.2026.

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HC-KAR NC: 2026:KHC:29345 WP No. 6955 of 2026

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 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 *Retyped and Replaced vide Chamber order dated 09.09.2026.

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HC-KAR NC: 2026:KHC:29345 WP No. 6955 of 2026

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.

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. *Retyped and Replaced vide Chamber order dated 09.09.2026.

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HC-KAR NC: 2026:KHC:29345 WP No. 6955 of 2026

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 – 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 – *Retyped and Replaced vide Chamber order dated 09.09.2026.

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HC-KAR NC: 2026:KHC:29345 WP No. 6955 of 2026

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 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 *Retyped and Replaced vide Chamber order dated 09.09.2026.

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HC-KAR NC: 2026:KHC:29345 WP No. 6955 of 2026

PAN number is removed if it is found to be unjustified.

Sd/- (B M SHYAM PRASAD) JUDGE

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