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NC: 2026:KHC:4518

WP No. 1860 of 2026

HC-KAR

IN THE HIGH COURT OF KARNATAKA AT BENGALURU

DATED THIS THE 28^TH DAY OF JANUARY, 2026

BEFORE

THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV

WRIT PETITION NO. 1860 OF 2026 (T-IT)

BETWEEN:

JITENDRA MOHANDAS VIRWANI

S/O MOHANDAS VIRWANI,

AGED ABOUT 59 YEARS,

RESIDING AT

NO.341, EMBASSY WOODS,

6A CUNNINGHAM ROAD,

VASANTH NAGAR,

BANGALORE-560 051.

…PETITIONER

(BY SRI. A. MAHESH CHOWDHARY, ADVOCATE A/W

KUM. KRISHIKA VAISHNAV, ADVOCATE)

AND:

1. DEPUTY COMMISSIONER OF INCOME TAX

Digitally

signed by CENTRAL CIRCLE 1(3)

VIDYA G R

CENTRAL REVENUE BUILDING

Location:

QUEENS ROAD

HIGH

COURT OF BENGALURU-560 001.

KARNATAKA

2. PRINCIPAL COMMISSIONER OF INCOME TAX

CENTRAL CIRCLE

CENTRAL REVENUE BUILDING

QUEENS ROAD

BENGALURU-560 001.

…RESPONDENTS

(BY SRI. DILIP, ADVOCATE)

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NC: 2026:KHC:4518

WP No. 1860 of 2026

HC-KAR

THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF

THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE

IMPUGNED ORDER DATED 22.12.2025, F.NO.119(2)(b)/

PR.CIT(C)/2025-26/10 PASSED BY THE PRINCIPAL

COMMISSIONER OF INCOME TAX (CENTRAL), BENGALURU,

REJECTING THE PETITIONER'S APPLICATION UNDER SECTION

119(2)(B) OF THE INCOME-TAX ACT, 1961 VIDE ANNEXURE-P

AS IT IS ARBITRARY AND ILLEGAL AND ETC.

THIS PETITION, COMING ON FOR PRELIMINARY

HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE S SUNIL DUTT YADAV

ORAL ORDER

Petitioner has called in question the correctness of

the order dated 22.12.2025 at Annexure-P passed by the

Principal Commissioner of Income Tax (Central),

Bangalore, rejecting the application filed under Section

119(2)(b) of the Income Tax Act, 1961 seeking

condonation of delay for filing revised returns.

2. The order at Annexure-P impugned in the

present writ petition would observe that in light of the

CBDT Circular No. 11/2024 dated 01.10.2024, there is no

provision to entertain an application beyond 5 years from

the end of the relevant assessment year.

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NC: 2026:KHC:4518

WP No. 1860 of 2026

HC-KAR

3. It is the case of the petitioner that the

petitioner had filed an original return of income for the

assessment year 2018-19 disclosing advance tax and self-

assessment tax paid. It is submitted that subsequently

petitioner had received intimation under Section 143(1)(a)

for the assessment year 2018-2019 raising a demand. It is

at that point of time, petitioner realised that there was an

error in the declaration made in the return filed insofar as

the details that were to be filled under 'Schedule E1'

relating to Exempt Income.

4. Learned counsel for the petitioner has filed

along with a memo the table demonstrating the error in

the declaration. The same is extracted below:

ORIGINAL RETURNS FILED ON 30.09.2018

Acknowledgement number:316329811300918 Assessment Year:2018-19

2 Embassy AAGFE0427K No No 0 0 0

Buildcon

LLp

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NC: 2026:KHC:4518

WP No. 1860 of 2026

HC-KAR

3 Saltire Estate ACSFS3615D No No 0 0 0

and resorts LLP

4 Sporthorse Stud ACZFS3170J No No 0 0 0

Book(India) LLp

5 Embassy Motion AAEFE0298A No No 0 0 0

Picture LLp

6 Mall Venture AAPFM3773M No No 0 0 0

7 Global Façade AAFFG7028R No No 0 0 0

Solutions

8 OMR Investment AACF08864E No No 0 0 0

LLP

Total

Schedure EI:Details of Exempt Income (Income not to be included in Total Income)

1 Interest Income 1 0

2 Dividend Income from domestic company 2 36487775

(amount not exceeding Rs.10 lakh)

3 Long-term capital gains from transactions 3 0

on which Securities Transaction Tax is

paid

4 I Gross Agricultural receipts (other I 0

than income to be excluded under

rule 7A, 7B or 8 of I.T. Rules)

II Expenditure incurred on II 0

agriculture

III Unabsorbed agricultural loss of III 0

previous eight assessment years

IV Net Agricultural Income for the 4 0

year (I-II-III) (enter nil if loss)

5 Others, including exempt Income of minor child (please specify)

S.No Nature of Income Amount

Total 0

6 Total (1+2+3+4+5) 6 36487775

Schedule PTI:Pass Through Income details from business trust or Investment fund as

per section 115UA, 115UB

RECTIFIED RETURNS FILED ON 10.09.2020

Acknowledgement number:5