M/S Classic Featherlite Waterfront Developers LLP Vs Assessment Unit.

THE LIMITED LIABILITY PARTNERSHIP ACT, 2008 HAVING OFFICE AT 678, CLASSIC HOUSE, 6^TH A CROSS, 17^TH MAIN, 3^RD BLOCK, KORAMANGALA, BANGALORE - 560034.

¶12

…PETITIONER

¶13

Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA

¶14

(BY MS. MANASA ANANTHAN., ADVOCATE FOR SMT. TANMAYEE RAJKUMAR., ADVOCATE)

¶15

AND:

¶16

ASSESSMENT UNIT., INCOME-TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE, ROOM NO. 401, 2^ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI 110003.

¶17

2 - NC: 2026:KHC:25484 WP No. 15921 of 2026

¶18

HC-KAR

¶19

INCOME-TAX OFFICER, WARD 1(2)(1) BMTC BUILDING, 6^TH BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE 560 095.

¶20

PRINCIPAL COMMISSIONER OF INCOME-TAX - 1, 5^TH FLOOR, BMTC BUILDING, 6^TH BLOCK, 80 FEET ROAD, KORAMANGALA BANGALORE 560095.

¶21

…RESPONDENTS

¶22

(BY SRI.Y.V. RAVIRAJ AND SRI VINAYAKA G PANDIT, , ADVOCATES)

¶23

THIS WP IS FILED UNDER ARTICLES 226 OF THE CONSTITUTION OF INDIA PRAYING TO (A) QUASHING THE ORDER DATED 18.03.2026 BEARING DIN ITBA/ AST/S/ 143(3)/ 2025-26/1087551060(1) (ANNEXUREG-1) PASSED BY THE 1 RESPONDENT UNDER SECTION 143(3) READ WITH SECTION 1448 OF THE ACT, FOR THE ASSESSMENT YEAR 2024-25; (B) QUASHING THE DEMAND NOTICE DATED 18.03.2026 BEARING DIN ITBA/AST/S/156/2025-26/1087551298(1) ISSUED BY THE 1 RESPONDENT (ANNEXURE 'G-2') TO THE PETITIONER UNDER SECTION 156 OF THE ACT FOR THE ASSESSMENT YEAR 2024-25; (C) QUASHING THE PENALTY NOTICE DATED 18.03.2026 BEARING DIN ITBA/PNL/S/270A/2025-26/1087553425(1) ISSUED BY THE 1^ST RESPONDENT (ANNEXURE - G-3) UNDER

¶24

3 - NC: 2026:KHC:25484 WP No. 15921 of 2026

¶25

HC-KAR

¶26

SECTION 274 READ WITH SECTION 270A OF THE ACT FOR THE ASSESSMENT YEAR 2024- 25.

¶27

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

¶28

CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD

¶29

ORAL ORDER

¶30

The short question for consideration is whether this Court must intervene with the assessment order relevant to the petitioner and the assessment year 2024-25, and this question is presented with the petitioner calling in question the assessment order dated 18.03.2026 [Annexure-G1] under Section 143(3) read with Section 144B of the Income Tax Act, 1961 [for short, 'the IT Act' ]. The petitioner has also called in question the demand/penalty notices [Annexures - G2 and G3].

¶31

Ms. Manasa Ananthan, the learned counsel for the petitioner, submits that the short ground urged is about the lack of a reasonable opportunity, and in elaboration, the learned counsel submits that the petitioner made a request on 10.03.2026 for extension of time [for

¶32

4 - NC: 2026:KHC:25484 WP No. 15921 of 2026

¶33

HC-KAR

¶34

adjournment by 10 days] and that the first respondent has completed the assessment proceedings by the impugned order without considering the request. The learned counsel submits that this Court may consider that the petitioner has not filed any response under the bonafide belief that the request for adjournment would be considered.

¶35

Mr. Vinayaka G. Pandit, the learned standing counsel

¶36

for the respondents, is heard in the light of the circumstances and the narrow canvas presented for consideration. This Court finds that the proceedings are completed with the aid of Section 144B of the IT Act without communication of a decision on the request for adjournment and this must suffice for this Court's interference to ensure that the proceedings are after a reasonable opportunity. Hence, the following:

¶37

ORDER

¶38

The petition is allowed-in-part quashing the impugned order and notices [Annexures - G1 to G3] restoring the proceedings for reconsideration with liberty to the petitioner to file reply and upload documents on the portal calling upon the authorities to ensure that there is

¶39