LIFELINE FEEDS (INDIA) PVT LTD vs. INCOME TAX OFFICER

WP/9636/2025HC KarnatakaKAHC01017299202509 April 2025Bench: S.R.KRISHNA KUMAR4 pages

AI SummaryPartly Allowed

What did the High Court hold?

The High Court of Karnataka disposed of the writ petition without expressing any opinion on the merits or demerits of the rival contentions. The court observed that it was an undisputed fact that the petitioner had not submitted a reply to the demand notices dated January 23, 2025, and February 25, 2025. Accordingly, the court directed the petitioner to appear before the respondent on May 5, 2025, and file a reply along with supporting documents to the aforementioned demand notices. The respondent was directed to consider the reply after providing sufficient opportunity to the petitioner. Furthermore, the court directed that until the respondent passes appropriate orders, no precipitative or coercive steps shall be taken against the petitioner. The issue of filing a revised TDS return was implicitly addressed by directing the petitioner to file a reply to the demand notices, which would likely encompass any rectifications or explanations.

What were the facts?

The petitioner, Lifeline Feeds (India) Pvt. Ltd., filed a writ petition before the High Court of Karnataka seeking to quash demand notices dated January 23, 2025, and February 25, 2025, issued by the Income Tax Officer, TDS Ward-1, Mysore. The petitioner also sought directions to refrain the respondent from initiating proceedings and to allow them to file a revised TDS return for assessment year 2024-25. The court noted that the petitioner had not submitted a reply to the demand notices. The petition was filed under Articles 226 & 227 of the Constitution of India.

What were the issues?

1. Whether the demand notices dated January 23, 2025, and February 25, 2025, issued by the Income Tax Officer, TDS Ward-1, Mysore, are liable to be quashed? (Question of law and fact, concerning the validity of the demand notices). 2. Whether the Income Tax Officer should be directed to refrain from initiating proceedings with respect to the impugned orders? (Question of law and fact, concerning the procedural actions of the respondent). 3. Whether the petitioner should be permitted to file a revised TDS return for assessment year 2024-25? (Question of law and fact, concerning the procedural rights of the petitioner). Assessee's Contentions: The petitioner sought to quash the demand notices, prevent further proceedings, and be allowed to file a revised TDS return. The specific grounds for quashing were not detailed in the provided text, but the prayer indicates a challenge to the demand notices and subsequent actions. Revenue's Contentions: The judgment does not record any specific contentions from the revenue. It only notes that learned counsel for the respondent appeared.

Which sections of the Income-tax Act were involved?

None explicitly mentioned in the provided text, beyond general reference to the Income Tax Act, 1961 and Articles 226 & 227 of the Constitution of India.

AI-generated summary — verify with the full judgment below

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NC: 2025:KHC:15270 WP No. 9636 of 2025

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 9TH DAY OF APRIL, 2025 BEFORE THE HON'BLE MR JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 9636 OF 2025 (T-IT) BETWEEN:

LIFELINE FEEDS (INDIA) PVT. LTD., II FLOOR, YASHORAM CHAMBER, RATHNAGIRI ROAD, CHIKMAGALUR, KARNATAKA INDIA – 577 101. REG. UNDER COMPANIES ACT, 1956 REP. BY MR. K. KISHORE KUMAR HEGDE, PAN: AAACL4299H TAN: BLRL00688C …PETITIONER (BY SMT. SHEETAL BORKAR, ADVOCATE)

AND:

INCOME TAX OFFICER, INCOME TAX DEPARTMENT OFFICE, TDS WARD-1, MYSORE – 570 010. …RESPONDENT (BY SRI. ARAVIND V.CHAVAN, ADVOCATE)

THIS WRIT PETITION IS FILED UNDER ARTICLE 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO DIRECTING THE CONCERNED COMPETENT RESPONDENT AUTHORITY TO QUASH THE DEMAND NOTICE ISSUED ON DATED 23.01.2025 VIDE DIN NO. ITBA/COM/F/17/2024-25/1072464302(1) ORDER PASSED UNDER THE INCOME TAX ACT 1961 VIDE ANNEXURE-B PASSED BY THE RESPONDENT AUTHORITYDIRECTING THE RESPONDENT AUTHORITY AND ETC.

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

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

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

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NC: 2025:KHC:15270 WP No. 9636 of 2025

ORAL ORDER In this petition, petitioner seeks for the following reliefs: “a) Issue a Writ of Mandamus or in the like nature of writ, directing the concerned competent respondent authority to quash the demand notice, issued on dated 23.01.2025 vide DIN No. ITBA/COM/F/17/2024_25/1072464302(1) order passed under the Income Tax Act, 1961; vide ANNEXURE-B passed by respondent authority. b) Issue Writ of Mandamus or in the like nature of writ of direction, directing the respondent authority to refrain from initiating any kind of proceedings with respect to the impugned Order issued on dated 23.01.2025 vide DIN No.ITBA/COM/F/17/2024_25/1072464302( 1) order passed under the Income Tax Act, 1961; vide ANNEXURE 6 passed by respondent authority.

c) Issue a writ of mandamus or in the like nature of it directing the concerned competent respondent authority to quash the demand notice issued on dated 25.02.2025 vide DIN number 25022025/00473CD order fast under the Income Tax Act 1961, vide an Annexure- 81 passed by the respondent authority.

d) issue a Writ of Mandamus or in the like nature of writ of direction, directing the concerned competent respondent authority to refrain from initiating any kind of proceedings with respect to the impugned order issued on dated 25.02.2025 vide DIN number 25022025/00473CD order passed under the Income Tax Act 1961. Vide Annexure-B1.

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NC: 2025:KHC:15270 WP No. 9636 of 2025

e) Issue a Writ of Prohibition or any other writ of like nature, directing the respondent not to proceed with coercive steps by way of any proceedings of whatsoever in nature, till disposal of this Writ Petition; and

f) Issue a writ of mandamus or in the like nature of writ. directing the concerned respondent authority to file revise TDS return for the relevant assessment year 2024- 25.

g) Issue a writ of prohibition or any other writ of like nature directing the respondent not to proceed with the cursive steps by way of any proceedings of whatsoever in nature till disposal of this writ petition and

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

Heard learned counsel for the petitioner, learned counsel for the respondent and perused the material on record. 3. Though several contentions have been urged by both sides in support of their respective claims, it is an undisputed fact borne out from the material on record that petitioner has not submitted its reply to Demand Notices dated 23.01.2025 and 25.02.2025 at Annexures-B and B1 respectively, without expressing any opinion on the merits / de-merits of the rival contentions, I deem it just and appropriate to dispose of this

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NC: 2025:KHC:15270 WP No. 9636 of 2025

petition reserving liberty in favour of the petitioner to submit reply to Demand Notices at dated 23.01.2025 and 25.02.2025 at Annexures-B and B1 respectively. 4. Accordingly, I pass the following: ORDER

i) The petition is hereby disposed of. ii) The petitioner is directed to appear before the sole respondent on 05.05.2025, on which date, he shall file reply along with documents to Demand Notices dated 23.01.2025 and 25.02.2025 at Annexures-B and B1 respectively, which shall be considered by the respondent after providing sufficient opportunity to the petitioner. iii) It is further directed that till respondent passes appropriate orders, shall not take any precipitative/coercive steps against the petitioner. Sd/- (S.R.KRISHNA KUMAR) JUDGE

MDS List No.: 2 Sl No.: 27

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