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Karnataka High Court

Mphasis Limited vs The Deputy Commissioner Of Income Tax on 17 October, 2025

Author: S.R.Krishna Kumar

Bench: S.R.Krishna Kumar

                                              -1-
                                                             NC: 2025:KHC:41590
                                                       WP No. 24925 of 2024


                HC-KAR




                    IN THE HIGH COURT OF KARNATAKA AT BENGALURU

                         DATED THIS THE 17TH DAY OF OCTOBER, 2025

                                           BEFORE
                       THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
                            WRIT PETITION NO.24925 OF 2024 (T-IT)
               BETWEEN:

               MPHASIS LIMITED
               1ST FLOOR WTC, 3RD BLOCK B,
               BAGMANE WORLD TECHNOLOGY CENTRE,
               K R PURAM, MARATHAHLLI, OUTER RING ROAD,
               DOODENEKUNDI,
               BENGALURU - 560 048 .
               PAN NO.AAACB6820C
               A COMPANY INCORPORATED UNDER
               THE COMPANIES ACT, 1956 AND
               REPRESENTED BY ITS AUTHORIZED SIGNATORY
               MR ARIJIT GANGULY
               S/O AMITAVA GANGULY
               AGED ABOUT 52 YEARS
               OCCUPATION: SENIOR VICE PRESIDENT
               AND GROUP HEAD TAXATION
Digitally
               RESIDING AT BAGAMANE TECHNOLOGY PARK,
signed by
CHANDANA       LAUREL BUILDING, C V RAMAN NAGAR
BM             BENGALURU - 560 003.
                                                                   ...PETITIONER
Location:
High Court     (BY SRI. ANKUR PAI DHUNGAT, ADVOCATE)
of Karnataka
               AND:

               1.     THE DEPUTY COMMISSIONER OF INCOME TAX
                      CIRCLE 4 (1) (1), ROOM NO.230,
                      2ND FLOOR, BMTC BUILDING,
                      80 FEET ROAD, KORAMANGALA
                      BENGALURU - 560 095.

               2.     ASSESSMENT UNIT / INCOME TAX OFFICER
                      INCOME TAX DEPARTMENT,
                                    -2-
                                                   NC: 2025:KHC:41590
                                               WP No. 24925 of 2024


 HC-KAR



     MINISTRY OF FINANCE,
     GOVERNMENT OF INDIA,
     NORTH BLOCK,
     NEW DELHI - 110 001.

3.   THE PRINCIPAL COMMISSIONER OF INCOME TAX
     BMTC BUILDING, 80 FEET ROAD,
     KORAMANGALA
     BENGALURU - 560 095.

4.   THE CHIEF COMMISSIONER OF INCOME TAX BENGALURU - 1
     CR BUILDING, QUEENS ROAD,
     BENGALURU - 560 001.
                                             ...RESPONDENTS
(BY SRI.SUSHAL TIWARI, ADVOCATE)


     THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE
CONSTITUTION OF INDIA PRAYING TO ORDER OR DIRECTION TO R1 TO
DISPOSE OF THE RECTIFICATION APPLICATION DATED 07/03/2024
(ANNX-J) AT THE EARLIEST.

      THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS
DAY, ORDER WAS MADE THEREIN AS UNDER:



CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR


                            ORAL ORDER

In this petition, petitioner has sought for the following reliefs:

"(i). Issue a writ of mandamus or any other writ, order or direction to the respondent No.1 to dispose of the rectification application dated 07.03.2024 (Annexure-'J') at the earliest;
(ii). Issue a writ of mandamus or any other writ, order or direction to the Respondents to issue the refund of excess DDT paid of Rs.41.56 Crores to the petitioner along with interest from the date of determination of refund till the -3- NC: 2025:KHC:41590 WP No. 24925 of 2024 HC-KAR date of actual refund, as per the provisions of Section 244A of the IT Act;
(iii). Issue any other writ, order or direction to which the petitioner is found entitled to in the present facts and circumstances."

2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record.

3. It is the grievance of the petitioner that its rectification application dated 07.03.2024 at Annexure - J submitted to the respondents has not been considered so far by the respondents nor any order has been passed on the same. Under these circumstances, the petitioner is before this Court by way of the present petition.

4. Per contra, learned counsel for the respondents submits that if reasonable time is given, the respondents would consider and pass necessary order on the said application.

5. In view of the aforesaid facts and circumstances and rival submissions, the respondents are hereby directed to address the grievances of the petitioner and consider his rectification application dated 07.03.2024 at Annexure - A and pass -4- NC: 2025:KHC:41590 WP No. 24925 of 2024 HC-KAR appropriate orders bearing in mind the material on record produced by the petitioner and in accordance with law, within a period of six weeks from the date of receipt of a copy of this order.

6. With the aforesaid directions, the petition stands disposed of.

Sd/-

(S.R.KRISHNA KUMAR) JUDGE SV List No.: 2 Sl No.: 1