IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18^TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 33155 OF 2025 (T-IT)

BETWEEN:

M/S INDIA RADIO VENTURES PRIVATE LIMITED NO.212, DOMLUR, 2^ND STAGE, 1^ST MAIN ROAD, INDIRANAGAR, BANGALORE – 560 071 (REPRESENTED BY ITS DIRECTOR MR. KORODI SANJAY PRABHU, AGED ABOUT 63 YEARS S/O MR. VASUDEV KORODI)

REGISTERED UNDER COMPANIES ACT 1956 …PETITIONER (BY SRI. NARENDRA KUMAR J. AND SMT. GEETHA RANI K., ADVOCATES)

AND:

1. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BMTC BUILDING, Di gitally 6^TH FLOOR, KORAMANGALA, signed by BENGALURU – 560 027 MADHURI S Location : 2. THE COMMISSIONER OF INCOME TAX APPEALS (1)

High Court of NATIONAL FACELESS ASSESSMENT CENTRE, Karnataka CENTRAL BOARD OF DIRECT TAXES, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2^ND FLOOR, E-RAMP, JAWARHARLAL NEHRU STADIUM, DELHI – 110 003

3. THE INCOME TAX OFFICER WARD 3(1)(1) BMTC BUILDING, KORAMANGALA, BENGALURU – 560 027 …RESPONDENTS (BY SRI. M. THIRUMALESH, ADVOCATE)

THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TON ISSUE AS FAR AS PETITIONER IS CONCERNED BY AN APPROPRIAT