IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 17^TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 20822 OF 2023 (T-IT)

BETWEEN:

MOORTHEDHARARA SEVA SAHAKARAI SANGHA NIYAMITHA A CO OPERATIVE SOCIETY REGISTERED UNDER THE KARNATAKA CO OPERATIVE SOCIETY ACT 1959, REGISTERED ADDRESS AT UPPINANGADY, PUTTUR, D.K.DISTRICT – 574 241, REP. BY ITS CEO SRI DEEKAYYA, SON OF SRI CHENNAPPA POOJARY, AGED ABOUT 44 YEARS.

…PETITIONER (BY SRI. ABHIJITH S. BAPU AND SRI. SHREEHARI KUTSA, ADVOCATES)

AND:

PRINCIPAL COMMISSIONER OF INCOME TAX PCIT, PANAJI Digitally AAYKAR BHAVAN, PLOT NO.05, signed by EDC COMPLEX, PATTO PLAZA, CHANDANA PANAJI GAO – 403 001, B M AN AUTHORITY UNDER Location:

THE INCOME TAX ACT 1961, High Court …RESPONDENT of Karnataka (BY SRI. SUSHAL TIWARI, ADVOCATE)

THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ORDER U/S 119(2)(b) OF THE INCOME TAX ACT, 1961 DTD 03/01/2023 ISSUED BY THE RESPONDENT FOR THE ASSESSMENT YEAR 2018-19 BEARING F.NO. 87/119(2)(b)/PR.CIT-PNJ/2022-23 AND BEARING THE DIN NO. ITBA/COM/M/17/2022-23/1048408066(1) WHICH IS ENCLOSED AS ANNEXURE-G1 AND ETC., THIS PETITION, CO