M/S SIGNION SYSTEMS PVT LTD vs. COMMISSIONER INCOME TAX

WP/17209/2025HC KarnatakaKAHC01037185202514 July 2025Bench: SURAJ GOVINDARAJ3 pages

AI SummaryWithdrawn

What did the High Court hold?

The High Court of Karnataka allowed the petitioner to withdraw the writ petition with liberty to file a fresh petition before the High Court of Telangana. The Court did not decide on the merits of the refund adjustment or the underlying tax demand. The reasoning was based on the petitioner's request, citing that both the petitioner and the respondent income tax authorities (Deputy and Assistant Commissioners) were based in Hyderabad, and the learned counsel for the petitioner sought permission to pursue the matter in the appropriate jurisdiction. The operative direction was to dispose of the petition as withdrawn, reserving the liberty for the petitioner to approach the Telangana High Court.

What were the facts?

The petitioner, M/s. Signion Systems Pvt. Ltd., filed a writ petition before the High Court of Karnataka. The petition challenged the adjustment of a refund of Rs. 19,09,630/- determined for Assessment Year 2020-21 towards a demand for Assessment Year 2019-20. The petitioner had made a representation/application dated 12/05/2025 to the Commissioner Income Tax (CPC) seeking this refund. The demand for AY 2019-20 was confirmed by rectification orders dated 21/07/2023 and 05/04/2024. The petitioner sought a direction to refund the amount within one month. The petitioner's registered office and the respondent income tax authorities (Deputy Commissioner and Assistant Commissioner) were located in Hyderabad.

What were the issues?

1. Whether the High Court of Karnataka has the territorial jurisdiction to entertain a writ petition concerning an assessee and tax authorities located in Hyderabad, when the primary challenge is to an adjustment of refund by the Centralized Processing Centre (CPC) in Bengaluru? Assessee's Contention: The petitioner sought to withdraw the petition with liberty to file a fresh petition before the High Court of Telangana, implying a potential issue with jurisdiction or convenience. Revenue's Contention: No specific arguments were recorded for the revenue in the provided judgment excerpt.

AI-generated summary — verify with the full judgment below

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HC-KAR NC: 2025:KHC:26000 WP No. 17209 of 2025

IN THE HIGH COURT OF KARNATAKA AT BENGALURU

DATED THIS THE 14TH DAY OF JULY, 2025

BEFORE

THE HON'BLE MR. JUSTICE SURAJ GOVINDARAJ

WRIT PETITION NO. 17209 OF 2025 (T-IT)

BETWEEN:

M/S. SIGNION SYSTEMS PVT. LTD., A PRIVATE LIMITED COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956, HAVING ITS REGISTERED OFFICE AT 71 AND 72, ANRICH, IDA BOLLARAM, HYDERABAD - 502 325. REPRESENTED BY ITS AUTHORISED REPRESENTATIVE MR. SRIRAM JAYASIMHA. …PETITIONER

(BY SRI. SIDDHARTH B. MUCHANDI, ADVOCATE)

AND:

COMMISSIONER INCOME TAX CENTRALIZED PROCESSING CENTRE (CPC), INCOME-TAX DEPARTMENT, BENGALURU - 560 500. 2. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE- 3 (1), 7TH FLOOR, SIGNATURE TOWERS, KONDAPUR, HYDERABAD - 500 084.

ASST. COMMISSIONER OF INCOME TAX CIRCLE- 3 (1), 7TH FLOOR, SIGNATURE TOWERS,

Digitally signed by SHWETHA RAGHAVENDRA Location: HIGH COURT OF KARNATAKA

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HC-KAR NC: 2025:KHC:26000 WP No. 17209 of 2025

KONDAPUR, HYDERABAD - 500 084. …RESPONDENTS

(BY SRI. ARVIND V. CHAVAN, ADVOCATE)

THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO CONSIDER THE REPRESENTATION/APPLICATION DATED 12/05/2025 (ANNEXURE-E) BEARING NO.SSPL/CPC/25-26/002 FILED BY THE PETITIONER BEFORE THE RESPONDENT NO.1 AND REFUND A SUM OF AMOUNT OF RS.19,09,630/- WHICH BEING THE REFUND DETERMINED FOR THE ASSESSMENT YEAR 2020- 21 ERRONEOUSLY ADJUSTED TOWARDS THE DEMAND FOR THE ASSESSMENT YEAR 2019-20, WHICH IS ALSO CONFIRMED AS PER THE RECTIFICATION ORDER BEARING NO.ITBA/REC/S/ 154-1/2023-24/105450883(1) DATED 21/07/2023 (ANNX-A) AND RECTIFICATION ORDER BEARING NO.ITBA/REC/S/154- 1/2024-25/1063927430(1) DATED 05/04/2024 (ANNX-B) WITHIN 1 (ONE) MONTH.

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

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HC-KAR NC: 2025:KHC:26000 WP No. 17209 of 2025

CORAM: HON'BLE MR. JUSTICE SURAJ GOVINDARAJ

ORAL ORDER

The petitioner being from Hyderabad and respondent Nos.2 and 3, who are Deputy Commissioner and Assistant Commissioner respectively, also being from Hyderabad, learned counsel for the petitioner seeks permission to withdraw the above petition with liberty to file a fresh petition in High Court of Telangana.

Reserving such liberty, the petition stands disposed of.

SD/- (SURAJ GOVINDARAJ) JUDGE

VM List No.: 2 Sl No.: 8 CT: BHK

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