Reserved on : 01.04.2026 Pronounced on : 24.04.2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24^TH DAY OF APRIL, 2026 PRESENT THE HON'BLE MR. JUSTICE S.G.PANDIT AND THE HON'BLE MR. JUSTICE K. V. ARAVIND WRIT APPEAL No. 382 OF 2026 (T-IT)

BETWEEN:

1. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(4), No.1, C.R. BUILDING, QUEENS ROAD, BENGALURU-560 001.

2. THE PR. COMMISSIONER OF INCOME TAX, CENTRAL RANGE-1, C.R. BUILDING, QUEEN'S ROAD, BENGALURU-560 001.

…APPELLANTS Digitally signed by (BY SRI. RAVI RAJ Y. V., SENIOR STANDING COUNSEL A/W VINUTHA B S SRI M. DILIP, STANDING COUNSEL)

Location:

High Court of Karnataka AND:

1. SRI C. R. RAM MOHAN RAJU, S/O. CHANGAMARAJU, AGED ABOUT 52 YEARS, RESIDING AT 24, 4^TH CROSS, K.R. LAYOUT, J.P. NAGAR, 6^TH PHASE, BENGALURU-560 078.

…RESPONDENT (BY SRI A. SHANKAR, SENIOR ADVOCATE A/W SRI CHANDRASEKHAR V., ADVOCATE)

THIS WRIT APPEAL IS FILED UNDER SECTION 4 OF THE KARNATAKA HIGH COURT ACT PRAYING TO SET ASIDE THE ORDER PASSED BY THE LEARNED SINGLE JUDGE IN WP No.

33057/2024 (T-IT) DATED 27.10.2025 THIS APPEAL HAVING BEEN HEARD AND RESERVED FOR JUDGMENT, COMING ON FOR PRONOUNCEMENT THIS DAY, K.V. ARAVIND J., DELIVERED THE FOLLOWING:-

CO