IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 6^TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 24139 OF 2025 (T-IT)

BETWEEN:

VIHAAN DIRECT SELLING (INDIA)

PRIVATE LIMITED A PRIVATE LIMITED COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956, CHICAGO AVENUE, S-203, 2^ND FLOOR, CUNNINGHAM ROAD, BENGALURU – 560 052 REPRESENTED BY ITS DIRECTOR MR. MUHAMMED IMTHIAZ, SON OF MR. MUHAMMED IQBAL, AGED ABOUT 52 YEARS …PETITIONER (BY SRI. SHREEHARI KUTSA, ADVOCATE)

AND:

1. THE PRINCIPAL COMMISSIONER OF INCOME TAX Digitally signed (CENTRAL) BENGALURU by CHANDANA B M BENGALURU Location: H igh AN AUTHORITY UNDER SECTION 116 Court of OF THE INCOME ACT, 1961 Karnataka CENTRAL REVENUE BUILDING, BENGALURU – 560 001

2. THE DIRECTOR GENERAL OF INCOME TAX, INVESTIGATION, DGIT (INVESTIGATION), BENGALURU, AN AUTHORITY UNDER SECTION 116 OF THE INCOME ACT, 1961, CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU – 560 001

3. THE ADDITIONAL COMMISSIONER OF INCOME TAX, (CENTRAL RANGE)-2, BENGALURU, AN AUTHORITY UNDER SECTION 116 OF THE INCOME ACT, 1961, CENTRAL REVENUE BUILDING, QUEEN’S ROAD, BENGALURU – 560 001

4. THE DEPUTY COMMISSIONER OF INCOME TAX, (CENTRAL CIR