M/S WIPRO ENTERPRISES PRIVATE LIMITED vs. THE COMMISSIONER OF INCOME TAX (APPEALS)

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WP/23180/2025HC KarnatakaKAHC01051019202531 October 2025Bench: S.R.KRISHNA KUMAR6 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court disposed of the writ petition in terms of the memo filed by the petitioner. The memo stated that following the filing of the writ petition, the rectification application filed by the petitioner before the 4th Respondent was disposed of by an order dated August 28, 2025. This rectification order corrected certain adjustments in the computation sheet as mistakes apparent from the records and determined that a sum of Rs. 74,40,019/- was refundable to the petitioner, which amount has since been paid. Consequently, the petitioner submitted that prayers (i) to (iv) of the writ petition had become infructuous. Prayer (v) was also considered infructuous. Regarding prayers (vi) and (vii), which pertained to the intimation dated July 29, 2023, the petitioner sought and was granted liberty to pursue its remedies against the same in accordance with law before the appropriate authorities, if necessary. The court accepted these submissions and disposed of the petition accordingly.

What were the facts?

The petitioner, M/s Wipro Enterprises Private Limited, filed a writ petition before the High Court of Karnataka challenging various orders related to its income tax assessment for Assessment Year 2022-23. The petitioner sought to quash a computation sheet and demand notice dated March 18, 2024, issued by the Assessment Unit (2nd Respondent), which imposed a demand of Rs. 62,21,52,670/-. The petitioner also challenged an appellate order dated May 23, 2025, passed by the Commissioner of Income Tax (Appeals) (1st Respondent), and an intimation dated July 29, 2023, issued by the Centralized Processing Centre (3rd Respondent). The petitioner had filed a rectification application under Section 154 before the Deputy Director of Income Tax (4th Respondent) due to the delay in its disposal. Subsequently, the rectification application was disposed of on August 28, 2025, rectifying certain adjustments and determining a refund of Rs. 74,40,019/-, which was paid to the petitioner.

What were the issues?

1. Whether the computation sheet and demand notice dated March 18, 2024, issued by the 2nd Respondent under the Income Tax Act, 1961, for AY 2022-23, are liable to be quashed, particularly in light of the underlying assessment order accepting the petitioner's returns and a subsequent rectification order. 2. Whether the appellate order dated May 23, 2025, passed by the 1st Respondent under Section 250 of the Income-tax Act, 1961, for AY 2022-23, is liable to be quashed. 3. Whether the intimation dated July 29, 2023, issued by the 3rd Respondent under Section 143(1) of the Income-tax Act, 1961, for AY 2022-23, is liable to be quashed, and if liberty should be granted to pursue remedies against it. Assessee's Contentions: The petitioner argued that the computation sheet and demand notice imposed a significant demand despite the assessment order accepting its returns. It also highlighted the delay in the disposal of its rectification application, leading to the filing of the writ petition. Following the disposal of the rectification application, which resulted in a refund, the petitioner submitted that prayers (i) to (iv) had become infructuous. It also sought liberty to pursue remedies regarding the intimation dated July 29, 2023. Revenue's Contentions: No specific contentions for the revenue were recorded in the judgment as the matter was disposed of based on a memo filed by the petitioner.

Which sections of the Income-tax Act were involved?

Section 154,Section 143(1),Section 143(3),Section 144B,Section 156,Section 250

AI-generated summary — verify with the full judgment below

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HC-KAR NC: 2025:KHC:44124 WP No. 23180 of 2025

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 31ST DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO.23180 OF 2025 (T-IT) BETWEEN:

M/S WIPRO ENTERPRISES PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE PROVISIONS OF THE COMPANIES ACT, 1956 HAVING ITS REGISTERED OFFICE AT HOUSE NO.8, 7TH MAIN, 1ST BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE – 560 034. REPRESENTED HEREIN BY ITS CHIEF TAXATION OFFICER, MR. SURESH PARAMESWARAN. …PETITIONER (BY SRI. SANDEEP HUILGOL, ADVOCATE) AND:

1.

THE COMMISSIONER OF INCOME TAX (APPEALS) NATIONAL FACELESS APPEAL CENTRE,

INCOME TAX DEPARTMENT ROOM NO.245-A,

NORTH BLOCK, NEW DELHI - 110 001.

2.

THE ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE,

INCOME-TAX DEPARTMENT, 2ND FLOOR,

JAWAHARLAL NEHRU STADIUM

NEW DELHI - 110 003.

3.

THE DEPUTY DIRECTOR OF INCOME-TAX CENTRALIZED PROCESSING CENTRE,

BENGALURU INCOME TAX DEPARTMENT

BENGALURU - 560 500.

4.

THE DEPUTY COMMISSIONER OF INCOME-TAX,

CIRCLE 7(1)(1), BANGALORE BMTC BUILDING,

80 FEET ROAD, 6TH BLOCK,

Digitally signed by CHANDANA B M Location: High Court of Karnataka

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HC-KAR NC: 2025:KHC:44124 WP No. 23180 of 2025

KORAMANGALA

BENGALURU - 560 095. …RESPONDENTS (BY SRI. SUSHAL TIWARI, ADVOCATE FOR R-1, R-2 & R-4; SRI. ARAVIND.V. CHAVAN, ADVOCATE FOR R-3)

THIS W.P IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE IMPUGNED COMPUTATION SHEET DATED 18.03.2024 BEARING DIN AND DOCUMENT NO. ITBA/AST/S/622/2023 24/1062848465(1) ISSUED BY THE 2ND RESPONDENT UNDER THE INCOME-TAX ACT, 1961, FOR THE ASSESSMENT YEAR 2022-23 (ANNEXURE -B).

THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR

ORAL ORDER

In this petition, petitioner seeks the following reliefs:

“(i) Quashing the impugned computation sheet dated 18.03.2024 bearing DIN and Document No. ITBA/AST/S/622/2023-24/1062848465(1) issued by the 2nd Respondent under the Income tax Act, 1961, for the assessment year 2022-23 (Annexure-‘B’);

(ii) Quashing the impugned notice of demand dated 18.03.2024 bearing DIN and Notice No. ITBA/AST/S/156/2023-24/1062848137(1) issued by the 2nd Respondent under Section 156 of the Income-tax Act, 1961, for the assessment year 2022-23 (Annexure 'B-1');

(iii) Directing the 2nd Respondent to issue a fresh computation sheet strictly in accordance with the assessment order 18.03.2024 passed by the 2nd

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HC-KAR NC: 2025:KHC:44124 WP No. 23180 of 2025

Respondent under Section 143(3) read with Section 144B of the Income tax Act (Annexure 'E');

Without prejudice and in the alternative to this Hon'ble Court kindly granting the above prayers,

(iv) Directing the 4th Respondent to dispose off the Application for Rectification Under Section 154 dated 30.03.2024 (Annexure 'D') as expeditiously as possible and in accordance with law, and after granting the Petitioner a reasonable and effective opportunity of hearing and to submit further documents, if any;

In any event and in addition to this Hon'ble Court kindly granting the above prayers at (i) to (iii) or at (iv),

(v) Quashing the impugned appellate order dated 23.05.2025 bearing DIN and Order No. ITBA/NFAC/S/250/2025-26/1076421653(1) passed by the 1st Respondent under Section 250 of the Income-tax Act, 1961 for the Assessment Year 2022-23 (Annexure 'A');

In any event and in addition to this Hon'ble Court kindly granting the above prayers or a part thereof,

(vi) Quashing the intimation dated 29.07.2023 bearing DIN CPC/2223/A6/327715987 and Demand Reference No.2023202237174682570C issued by the 3rd Respondent under Section 143(1) of the Income-tax Act, 1961, for assessment year 2022-23 (Annexure 'C');

Without prejudice and in the alternative to this Hon'ble Court kindly granting the above prayer at (vi).

(vii) Permitting the Petitioner to file an application for rectification of the impugned intimation dated 29.07.2023 under Section 154 of the Income-tax Act, 1961 bearing DIN

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HC-KAR NC: 2025:KHC:44124 WP No. 23180 of 2025

CPC/2223/A6/327715987 and Demand Reference No. 2023202237174682570C for the assessment year 2022-23 (Annexure 'C'), before the 3rd or 4th Respondent forthwith with a consequent direction to the concerned Respondent to pass an order disposing off the said rectification application as expeditiously as possible and in accordance with law, and after granting the Petitioner a reasonable and effective opportunity of hearing and to submit further documents, if any; and

(viii) Pass such other or further orders as this Hon'ble Court may deem fit in the facts and circumstances of the case, and in the interests of justice and equity.”

2.

Learned counsel for the petitioner has filed a memo seeking to dispose of the petition in terms of the memo. The said memo along with documents are taken on record. “ MEMO ON BEHALF OF PETITIONER.

Pursuant to the present writ petition, the petitioner makes the following submissions before this Hon’ble Court:

1) The present writ petition is filed seeking the quashing of the impugned computation sheet and demand notice [Annexures ‘B’ and ‘B-1’ respectively] issued by the 2nd Respondent dated 18.03.2024, which foisted a demand of Rs.62,21,52,670/- upon the Petitioner for AY 2022-23, despite the underlying assessment order dated 18.03.2024 [Annexure ‘B’] accepting the petitioner’s income tax returns.

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HC-KAR NC: 2025:KHC:44124 WP No. 23180 of 2025

2) Subsequently, a rectification application was filed by the Petitioner before the 4th Respondent [Annexure-‘D’]. However, since the 4th Respondent did not dispose off the application for more than 6 months, the Petitioner filed this Writ Petition.

3) It is humbly submitted that after filing this Writ Petition, the said rectification application has now been disposed off by the 4th Respondent vide the Rectification Order under Section 154 of the Act on 28.08.2052 [produced as Document No.1 in the present Memo] rectifying the various adjustments made in the computation sheet as mistake apparent from the records, and holding that a sum of Rs.74,40,019/- is refundable. On instructions it is submitted that the said amount ahs also since been paid to the credit of the Petitioner.

4) In light of the above, this Hon’ble Court may be pleased to dispose off the writ petition as prayed hereunder:

a) That prayers (i) to (iv) as having become infructuous due to the 4th Respondent’s Rectification Order dated: 28.08.2025;

b) That prayer (v) be treated as infructuous since the same not longer survives for consideration in the light of the 4th Respondent’s Rectification Order dated: 28.08.2025; and

c) That, with respect to Prayers (vi) and (vii) which are in respect of the impugned intimation dated 29.07.2023 issued by the 3rd Respondent [Annexures ‘C’] liberty may kindly be granted to the Petitioner to pursue its

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HC-KAR NC: 2025:KHC:44124 WP No. 23180 of 2025

remedies against the same in accordance with law before the appropriate authorities, if necessary.

It is most humbly prayed that this Hon’ble Court may kindly be pleased to take this memo and enclosed document on record and dispose the preset writ petition in the aforementioned manner, in the interest of justice and equity.”

3.

Accordingly, petition is disposed of in terms of the aforesaid memo.

Sd/- (S.R.KRISHNA KUMAR) JUDGE

SV List No.: 2 Sl No.: 86

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