ALTISOURCE ASIA HOLDINGS LIMITED I vs. CENTRALIZED PROCESSING CENTRE
What did the High Court hold?
The High Court of Karnataka disposed of the writ petition as withdrawn. The court noted the submission by the learned counsel for the petitioner that due to the transfer of the file, the petitioner would need to avail a remedy before the third respondent. After hearing the learned standing counsels for the respondents, the petition was disposed of as withdrawn with liberty reserved to the petitioner, subject to just exceptions. No decision was made on the merits of the demand or rectification orders. The operative direction was to dispose of the petition as withdrawn with liberty.
What were the facts?
The petitioner, Altisource Asia Holdings Limited, a company incorporated outside India and represented by its authorized signatory, filed a writ petition before the High Court of Karnataka. The petition challenged a demand order dated December 14, 2025, passed by the Centralized Processing Centre (CPC) under Section 143(1) of the Income Tax Act, 1961, for Assessment Year (AY) 2024-25. The petitioner also challenged a rectification order dated January 7, 2026, passed by the CPC under Section 154 of the Income Tax Act, 1961, for the same AY. The petitioner sought to quash these orders and prevent the respondents from enforcing the demand. The respondents are the Centralized Processing Centre, Director General of Income Tax (Systems), and the Deputy Commissioner of Income Tax.
What were the issues?
1. Whether the demand order dated December 14, 2025, passed under Section 143(1) of the Income Tax Act, 1961, for AY 2024-25, is liable to be quashed? 2. Whether the rectification order dated January 7, 2026, passed under Section 154 of the Income Tax Act, 1961, for AY 2024-25, is liable to be quashed? Assessee's Contention: The petitioner sought to quash the impugned orders and prevent enforcement of the demand. The counsel for the petitioner submitted that due to the transfer of the file, the petitioner would have to avail a remedy before the third respondent (Deputy Commissioner of Income Tax). Revenue's Contention: The learned standing counsels for the respondents appeared and heard. No specific contentions are recorded in the judgment regarding the merits of the case.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
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HC-KAR NC: 2026:KHC:30353 WP No. 5287 of 2026
IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 19TH DAY OF JUNE, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 5287 OF 2026 (T-IT) BETWEEN:
ALTISOURCE ASIA HOLDINGS LIMITED I C/O TEMPLE CORPORATE SERVICES TEMPLE COURT, PORT LOUIS, STATE OUTSIDE INDIA MAURITIUS (REPRESENTED BY SOMNATH MITRA, AUTHORISED SIGNATORY) PRINCIPAL OFFICER, INCORPORATION UNDER THE COMPANIES ACT 1956 …PETITIONER (BY SRI. VISHWANATH K.,ADVOCATE)
AND:
CENTRALIZED PROCESSING CENTRE INCOME TAX DEPARTMENT, BENGALURU-560500. REP. BY ITS DIRECTOR.
DIRECTOR GENERAL OF INCOME TAX (SYSTEMS), POST BOX NO.2, ELECTRONIC CITY POST, BENGALURU-560500.
THE DEPUTY COMMISSIONER OF
Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA
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HC-KAR NC: 2026:KHC:30353 WP No. 5287 of 2026
INCOME TAX, DCIT/ACIT CIRCLE 1(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU-560095. …RESPONDENTS (BY SRI.ARAVIND V CHAVAN., ADVOCATE FOR A/W SRI. NIRMAL MATHEW., ADVOCATE FOR R1 AND R2; SRI. M. DILIP., ADVOCATE FOR R3)
THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO I) QUASHING OR SETTING THE DEMAND ORDER REFERENCE HAVING DIN ASIDE NUMBER CPC/2425/A6/624100718 WITH 2025202437419566746C DATED 14.12.2025 PASSED OR ISSUED BY THE RESPONDENT NO. 1 UNDER SECTION 143(1) OF THE INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR (AY) 2024-25 (ANNEXURE A) AND RECTIFICATION ORDER HAVING DIN CPC/2425/U6/635581276 AND DEMAND REFERENCE NO. 2025202437430726171C DATED 07.01.2026 PASSED OR ISSUED BY RESPONDENT NO.1 UNDER SECTION 154 OF THE INCOME TAX ACT, 1961 FOR THE AY 2024-25 (ANNEXURE-B); II) DIRECTING THE RESPONDENTS NOT TO ENFORCE OR INITATE OR PURSUE ANY PROCEEDINGS FOR RECOVERY OR ADJUSTMENT OF THE DEMAND OF TAX AND INTEREST FOR THE AY 2024-25 PURSUANT TO THE IMPUGNED ORDER TILL THIS WRIT PETITION IS DISPOSED OFF BY THE HONBLE COURT.
THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD
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HC-KAR NC: 2026:KHC:30353 WP No. 5287 of 2026
ORAL ORDER
When queried on the liberty that is reserved, Sri.Vishwanath K., the learned counsel for the petitioner, submits that because of the transfer of the file, the petitioner will have to avail remedy before the third respondent.
After hearing Sri Arvind V. Chavan and Sri Nirmal Mathew, the learned standing counsels for the first and second respondents and Sri M. Dilip, a learned standing counsel for the third respondent, the petition stands disposed of as withdrawn with liberty reserved subject to just exceptions.
Sd/- (B M SHYAM PRASAD) JUDGE
SA Ct:sr
More judgments on Section 154
- Income Tax Officer, Jaipur vs Rakesh Kumar Malani, JaipurITA 1425/JPR/2026[2025-26]Status: Disposed21 Oct 2026AY 2025-26
- Income Tax Officer, Jaipur vs Anita Sharma, JaipurITA 1344/JPR/2026[2024-25]Status: Disposed21 Oct 2026AY 2024-25
- Ramtirath Bawa, Nagpur vs ITO Ward3(4), NagpurITA 327/NAG/2026[2015-16]Status: Disposed16 Oct 2026AY 2015-16
- Mohinder Singh, Nagpur vs ITO Ward 3(4), NagpurITA 322/NAG/2026[2015-16]Status: Disposed16 Oct 2026AY 2015-16
- Ramakrishna Reddy Makireddy, Hyderabad vs ACIT, Circle-5(1), HyderabadITA 70/HYD/2026[2007-08]Status: Disposed16 Oct 2026AY 2007-08
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