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Karnataka High Court

Buckeye Trust vs Registrar on 18 September, 2025

Author: M.Nagaprasanna

Bench: M.Nagaprasanna

                                          -1-
                                                     NC: 2025:KHC:37479
                                                  WP No. 25280 of 2025


                HC-KAR




                     IN THE HIGH COURT OF KARNATAKA AT BENGALURU

                      DATED THIS THE 18TH DAY OF SEPTEMBER, 2025

                                         BEFORE
                       THE HON'BLE MR. JUSTICE M.NAGAPRASANNA
                         WRIT PETITION NO. 25280 OF 2025 (T-IT)


                BETWEEN:

                BUCKEYE TRUST
                REGISTERED UNDER
                THE INDIAN TRUST ACT, 1882
                PLOT NO.23, NADATHUR PLACE
                3RD FLOOR, 8TH MAIN ROAD
                3RD BLOCK, JAYANAGAR
                BENGALURU - 560 011
                REPRESENTED BY ITS
                AUTHORIZED REPRESENTATIVE
                NANDAN LAXMAN SASTRY.
Digitally
signed by
NAGAVENI                                                  ...PETITIONER
Location:       (BY SRI A.MAHESH CHOWDHARY.,ADVOCATE)
High Court of
Karnataka
                AND:

                1.    REGISTRAR
                      HON'BLE ITAT
                      BENGALURU - 51
                      1ST CROSS ROAD
                      3RD BLOCK EAST
                      4TH T BLOCK EAST
                      TILAK NAGAR
                                -2-
                                            NC: 2025:KHC:37479
                                          WP No. 25280 of 2025


HC-KAR



     JAYANAGAR
     BENGALURU - 560 041.



2.   PRINCIPAL COMMISSIONER OF INCOME TAX
     INCOME TAX OFFICE, BMTC BUILDING
     80FT ROAD, 6TH BLOCK
     NEAR KHB GAMES VILLAGE
     KORMANAGALA
     BENGALURU - 560 095.

3.   FACELESS ASSESSMENT UNIT
     ROOM NO.401, 2ND FLOOR, E-RAMP,
     JAWAHAR LAL NEHRU STADIUM,
     DELHI - 110 003.


                                                 ...RESPONDENTS
(BY SRI PRAMOD B., ADVOCATE FOR R-1;
     SRI M.DILIP, ADVOCATE FOR R2 AND R3)


      THIS WRIT PETITION IS FILED UNDER ARTICLE 226 AND
227 OF CONSTITUTION OF INDIA IS PRAYING TO DIRECTION
TO R1 TO DEFER THE PROCEEDINGS VIDE ANNEXURE-D
ITA/1051/24 DTD 30.12.2024 UNTIL THE DISPOSAL OF THE
PETITION     PENDING      BEFORE     PRESIDENT    HON'BLE   ITAT
MUMBAI, VIDE ANNEXURE-J ITA-1051/24.

      THIS    PETITION,     COMING     ON   FOR    PRELIMINARY

HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:
                                  -3-
                                                NC: 2025:KHC:37479
                                            WP No. 25280 of 2025


HC-KAR



CORAM:      HON'BLE MR. JUSTICE M.NAGAPRASANNA


                          ORAL ORDER

The petitioner is before this Court seeking the following prayer:

"a. Issue a writ of mandamus or an appropriate direction to Respondent No.1 to defer the proceedings vide Annexure-D ITA: 1051/24 dtd:30- 12-24 until the disposal of the petition pending President before Hon'ble ITAT Mumbai, vide Annexure J ITA-1051/2024 in the interest of justice and equity.
b. Any other relief/s as this Hon'ble Court deems fit in the interest of justice and equity."

2. Heard Sri A. Mahesh Chowdhary, learned counsel for petitioner, Sri Pramod B., learned counsel for respondent No.1 and Sri M. Dilip, learned counsel for respondent Nos.2 AND 3.

3. Owing to the submissions made on 19.08.2025, this Court had passed the following order:

"Heard the learned Senior Counsel Sri.K. Shashi Kiran Shetty appearing for the petitioner.
The petitioner is before this Court on a very strange circumstance. An adjudication of the rights of the petitioner takes place before the Income Tax Appellate Tribunal at the "A" Bench: Bangalore. The order is appended to the petition. The order prima facie indicates that it is Artificial intelligence driven. The indication is -4- NC: 2025:KHC:37479 WP No. 25280 of 2025 HC-KAR vindicated, by the subsequent order recalling the order as it was so rendered by the members of the Tribunal or before the Tribunal.
After the recall of the said order, it transpires that certain members have recused themselves as they were part of the order that was passed which is allegedly Artificial Intelligence driven. The Judicial Member who is said to be the author of the order that was recalled on an allegedly driven by Artificial Intelligence to a large extent, is now wanting to hear the matter. Learned Senior Counsel submits that, an application was filed to post the matter before any other Tribunal of the jurisdiction. The said application is pending consideration before the President. The learned Senior Counsel submits that if the concerned Judicial Member is permitted to go on and proceeding to pass orders, it would be hit by apparent bias or the concept that 'justice must not only be done but seem to have been done'.
In that light, further proceedings before the Tribunal shall remain stayed.
Learned counsel Sri.Jeevan J Neeralgi is directed to accept notice for respondent Nos.1 to 3.
The petitioner to serve set of papers upon the aforesaid counsel forthwith.
List on 21.08.2025 in Preliminary Hearing.
Interim order restraining the Judicial Member from hearing the matter will not come in the way of the President considering the application so filed by these petitioners seeking transfer of the proceeding to any other Tribunal."

Pursuant to the afore-quoted order, the matter is assigned to a different bench by the President of the Tribunal. With placing the matter before a different bench, learned counsel for the petitioner submits that the petition would be -5- NC: 2025:KHC:37479 WP No. 25280 of 2025 HC-KAR disposed as having become unnecessary, reserving liberty to the petitioner to avail of such remedy before the appropriate fora, if an order would be passed against him.

4. In the light of the said submission, reserving such liberty, the petition stands disposed as having become infructuous.

Sd/-

(M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 44