IN THE HIGH COURT OF KARNATAKA AT BENGALURU

DATED THIS THE 10^TH DAY OF DECEMBER, 2025

BEFORE

THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR

WRIT PETITION NO. 37241 OF 2025 (T-IT)

BETWEEN:

1. ERIC PRAKASH CYRIL D SA

AGED 58 YEARS,

S/O GRATIAN D'SA,

1-22, PRAKASH VIHAR, BAREBAIL,

BEJAI POST, MANGALORE,

DAKSHINA KANNADA - 575 004.

…PETITIONER

(BY SRI. RAVI SHANKAR S.V., ADVOCATE)

AND:

1. INCOME TAX OFFICER

INTERNATIONAL TAXATION WARD,

Digitally signed MANGALORE - 575 001.

by

SHARADAVANI

B

2. THE COMMISSIONER OF INCOME-TAX

Location: High

Court of (INTL TAXATION) BENGALURU,

Karnataka

BMTC BUILDING, 80 FEET ROAD,

6^TH BLOCK, KORAMANGALA,

BENGALURU - 560 095

…RESPONDENTS

(BY SRI. E.I. SANMATHI, ADVOCATE AND

SRI. SUSHAL TIWARI, ADVOCATE)

THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR A DIRECTION IN THE NATURE OF WRIT OF CERTIORARI QUASHING THE ORDER UNDER SECTION 119(2)(b) OF THE INCOME TAX ACT, 1961 (FOR SHORT THE ACT) DATED 21.08.2025 PASSED BY THE RESPONDENT NO.2 IN DIN NO.ITBA/COM/F/17/2025-26/1079823999(1) FOR THE ASSESSMENT YEAR 2022-23 (ANNEXURE-A).

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

CORAM: HON'BLE MR. J