IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 21^ST DAY OF FEBRUARY, 2026 BEFORE THE HON'BLE MR. JUSTICE M. NAGAPRASANNA WRIT PETITION No.18439 OF 2024 (T - IT)

C/W WRIT PETITION No.18474 OF 2024 (T - IT) IN WRIT PETITION No.18439 OF 2024 BETWEEN:

UNITED SPIRITS LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT 1956 AND HAVING ITS OFFICE AT UB TOWERS NO.24, VITTAL MALLYA ROAD BENGALURU – 560 001 REPRSENTED HEREIN BY ITS GENERAL MANAGER MR.JAYATHEERTHA KULKARNI ... PETITIONER (BY SRI MR.PERCY PARDIWALLA, SR.ADVOCATE FOR SMT.TANMAYEE RAJKUMAR, ADVOCATE)

AND:

1 . DEPUTY COMMISSIONER OF INCOME TAX TRANSFER PRICING 2(2)(2)

HAVING HIS OFFICE AT

80 FEET ROAD, BMTC BUILDING KORAMANGALA BENGALURU – 560 095.

2 . JOINT COMMISSIONER OF INCOME-TAX SPECIAL RANGE-7, HAVING HIS OFFICE AT

80 FEET ROAD, BMTC BUIDLING KORAMANGALA BENGALURU – 560 095.

3 . DEPUTY COMMISSIONER OF INCOME-TAX CENTRAL CIRCLE 2(1), HAVING HIS OFFICE AT C R BUILDING ANNEXE NO.1, QUEEN’S ROAD BENGALURU – 560 001.

4 . PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL)

HAVING OFFICE C R BUILIDNG, ANNEXE NO.1, QUEEN’S ROAD BENGALURU – 560 001.

... RESPONDENTS (BY SRI Y.V.RAVI RAJ, ADVOCATE)

THIS WRIT PETITION IS FILED UNDER ARTICL