IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 02.02.2026 CORAM THE HON'BLE MR JUSTICE C. SARAVANAN W.P.No.1635 of 2023 and W.M.P.Nos.1751 & 32730 of 2023 Sriram Moorthy Represented by his Power Agent Mr. V.Moorthy, Plot No. 801/ 81- A, Sigma Park Apartment, Park Road, Anna Nagar, West Extn., Chennai - 600101 ..Petitioner Vs

1. Commissioner of Income Tax (International Taxation), Chennai, 4th Floor, BSNL Building (Tower 1), No. 16, Greams Road, Chennai - 600006.

2. Income Tax Officer International Taxation 2(1), Chennai, 4th Floor, BSNL Building (Tower 1), No. 16, Greams Road, Chennai - 600006 ..Respondents PRAYER: Writ Petition filed under Article 226 of the Constitution of India, for issuance of a Writ of Certiorarified Mandamus, calling for the records on the file of the 1st respondent in CIT/ IT/CHE/112(264)/2022-23 and quash the impugned order dated 30.12.2022 passed under Section 264 of the Income tax Act, 1961 as illegal and not in accordance with law and consequently direct the

1st respondent.

For Petitioner : Mr.R.Sivaraman For Respondents : Mr.Avinash Krishnan Ravi, Junior Standing Counsel.

ORDER

In this Writ Petition, the petitioner has challenged the impugned order dated 3