ACI WORLDWIDE SOLUTIONS PRIVATE LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

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WP/19734/2025HC KarnatakaKAHC01041920202511 September 2025Bench: M.NAGAPRASANNA6 pages
AI SummaryRemanded

What did the High Court hold?

The High Court noted that the respondents, through their counsel, submitted that an order determining the refund amount in favour of the petitioner had been passed during the pendency of the writ petition, rendering the petition infructuous. The petitioner's counsel acknowledged this but pointed out that the refund had not yet been received, despite the order being 40 days old. The Court, in light of the submission that the refund had been determined and only its release remained, directed the respondents to release the determined refund amount within six weeks from the date of receipt of a copy of the order. The writ petition was disposed of with this direction. The specific issues regarding the rectification applications and the merits of the alleged mistakes were not decided on their substance, as the matter was resolved by the subsequent refund determination.

What were the facts?

The petitioner, ACI Worldwide Solutions Private Limited, filed a writ petition before the High Court of Karnataka. The petition challenged the inaction of the Deputy Commissioner of Income Tax (first respondent) in considering rectification applications dated July 24, 2024, and April 23, 2024, for assessment years 2020-21 and 2021-22, respectively. For AY 2020-21, a final assessment order dated July 9, 2024, was passed by the third respondent under Sections 143(3) r/w. 144C(13) r/w. Section 144B of the Income Tax Act, 1961, making additions for education cess. For AY 2021-22, an intimation order dated November 13, 2022, was passed by the second respondent. The petitioner sought a writ of mandamus to consider these applications and rectify the assessment/intimation orders, and also to grant refund along with interest under Section 244A(1).

What were the issues?

1. Whether the High Court should issue a writ of mandamus directing the first respondent to consider the petitioner's rectification application dated 24.07.2024 and rectify the final assessment order dated 09.07.2024 for AY 2020-21, as per Section 154 of the Income Tax Act, 1961? The petitioner contended that mistakes had inadvertently crept into the assessment order and that no rectification order was passed despite filing the application. The revenue did not record specific arguments on this issue, but later submitted that a refund order had been passed. 2. Whether the High Court should issue a writ of mandamus directing the first respondent to consider the petitioner's rectification application dated 23.04.2024 and rectify the intimation order dated 13.11.2022 for AY 2021-22? The petitioner argued that no order was passed on this application. The revenue did not record specific arguments on this issue, but later submitted that a refund order had been passed. 3. Whether the High Court should issue a writ of mandamus directing the respondents to grant refund along with interest under Section 244A(1) of the Income Tax Act, 1961, for AY 2020-21 & AY 2021-22? The petitioner sought this relief due to the alleged delay in processing their rectification applications and refund.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 154,Section 244A(1)

AI-generated summary — verify with the full judgment below

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HC-KAR NC: 2025:KHC:36172 WP No. 19734 of 2025

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 11TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 19734 OF 2025 (T-IT)

BETWEEN:

ACI WORLDWIDE SOLUTIONS PRIVATE LIMITED NO.9, SALARPURIA CAMBRDIGE MALL CAMBRIDGE ROAD ULSOOR BANGALORE - 560 008 REPRESENTED BY ITS DIRECTOR MRS. JYOTHSNA SHETTY AGED ABOUT 52 YEARS D/O MR. BOLA MANOHAR SHETTY) COMPANY REGISTERED UNDER COMPANIES ACT 1956 …PETITIONER (BY SRI. NARENDRA KUMAR J. JAIN, ADVOCATE)

AND:

1.

THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1)(1) 80 FEET ROAD KORAMANGALA BANGALORE - 560 095

2.

THE ASSISTANT DIRECTOR OF INCOME TAX CENTRAL PROCESSNIG UNIT, CPC INCOME TAX DEPARTMENT BENGALURU - 560 500

Digitally signed by NAGAVENI Location: High Court of Karnataka

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HC-KAR NC: 2025:KHC:36172 WP No. 19734 of 2025

3.

THE ADDITIONAL/JOINT/DEPUTY/ ASSISTANT COMMISSIONER OF INCOME TAX INCOME-TAX OFFICER ASSESSMENT UNIT INCOME TAX DEPARTMENT MINISTRY OF FINANCE ROOM NO.401, 2ND FLOOR E-RAMP, JAWAHARLAL NEHRU STADIUM DELHI - 110 003 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE)

THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO-ISSUE AS FAR AS PETITIONER IS CONCERNED BY AN APPROPRIATE WRIT OR ORDER IN THE NATURE OF MANDAMUS OR OTHERWISE, TO THE LEARNED FIRST RESPONDENT TO CONSIDER THE RECTIFICATION APPLICATION DATED 24.07.2024 ENCLOSED IN ANNEXURE B AND RECTIFY THE FINAL ASSESSMENT ORDER DATED 09.07.2024 ENCLOSED IN ANNEXURE A FOR AY 2020-21.

THIS PETITION, COMING ON FOR PRELIMINAR HEARING - B GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

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HC-KAR NC: 2025:KHC:36172 WP No. 19734 of 2025

CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA

ORAL ORDER

The petitioner is before this Court, seeking the following prayer: "A. Issue as far as Petitioner is concerned by an appropriate writ or Order in the nature of Mandamus or otherwise, to the Learned First Respondent to consider the rectification application dated 24.07.2024 enclosed as Annexure B and rectify the Final assessment Order passed by the Learned Third Respondent dated 09.07.2024 enclosed in Annexure A for AY 2020-21. B. Issue as far as Petitioner is concerned by an appropriate writ or order in the nature of Mandamus or otherwise, to the Learned First Respondent to consider the rectification application dated 23.04.2024 for AY 2021-22 enclosed in Annexure E and rectify the intimation order passed by the Learned Second Respondent dated 13.11.2022 enclosed in Annexure D. And C. Issue as far as Petitioner is concerned by an appropriate writ or Order in the nature of Mandamus or otherwise, directing the learned Respondent to grant refund along with interest as stipulated under section 244A(1) for AY 2020-21 & AY 2021-22. D. Grant such other reliefs as this Honourable High Court may think fit including the cost of this writ petition."

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HC-KAR NC: 2025:KHC:36172 WP No. 19734 of 2025

2.

Heard Sri. Narendra Kumar J. Jain, learned counsel appearing for the petitioner, Sri. M. Dilip, learned counsel appearing for the respondents and have perused the material on record. 3. For the assessment year 2020-2021, it is the averment in the petition that the third respondent has passed a final assessment order under Sections 143(3) r/w. 144C(13) r/w. Section 144B of the Income Tax Act, 1961 (for short ‘the Act’), making additions towards education cess for an amount of `44,81,083/- and determining the total income at `46,74,02,870/-. Owing to certain mistakes that are said to have inadvertently crept in, in the computation sheet attached to the assessment order, the first respondent has considered the total income at `46,74,02,873/-. The difference of `34,56,196/- was due to the dividend earned from mutual funds, which is added to the total income. 4. The petitioner then prefers a rectification application under Section 154 of the Act before the first respondent and no rectification order was passed. The same goes with

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HC-KAR NC: 2025:KHC:36172 WP No. 19734 of 2025

assessment year 2021-22. No order was passed. Therefore, the petitioner is before the Court seeking the aforesaid prayer. 5. Learned counsel appearing for the respondents on instructions and verification of the record would submit that during the subsistence of the petition, the order is passed by the first respondent determining the amount of refund in favour of the petitioner. Therefore, learned counsel submits that the petition is rendered infructuous. 6. Learned counsel for the petitioner submits that the order of determination of refund is 40 days old and no refund is yet reached the doors of the petitioner. Thus, learned counsel would seek a direction to the respondents to release the refund that is determined by the respondents, within a particular time that would be fixed by this Court. 7. In the light of the said submission of the learned counsel for the respondents that the refund is determined and what remains is its release, the refund amount so determined by the respondents shall be released within an outer limit of six (6) weeks from the date of receipt of a copy of this order.

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HC-KAR NC: 2025:KHC:36172 WP No. 19734 of 2025

8.

The writ petition thus, stands disposed with the aforesaid observation and direction.

Sd/- (M.NAGAPRASANNA) JUDGE

SJK List No.: 1 Sl No.: 106

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