The petitioner,. Satyam Computer Services Limited (now known as Tech Mahindra Limited), was embroiled in a major corporate scandal when its former Chairman, Mr. B. Ramalinga Raju, admitted to falsifying accounts, inflating income by Rs. 5,040 crores. This resulted in excess tax payments and distorted financial statements. Following government intervention and a change in management, the petitioner sought relief from the Central Board of Direct Taxes (CBDT) under Section 119(2)(b) of the Income Tax Act, requesting recomputation of income for Assessment Years 2003-04 to 2008-09 to reflect actual income and exclude fictitious amounts. Despite findings by investigative agencies like CBI, SFIO, and court rulings confirming the fraud, the CBDT rejected the application, citing lack of jurisdiction and absence of “genuine hardship.” The petitioner challenged the order  in the Telangana High Court, arguing that denial of relief contravened Article 265 of the Constitution, which mandates tax collection based solely on lawful income. The High Court held that the CBDT’s refusal ignored established fraud and the petitioner’s genuine hardship. It emphasized that tax cannot be levied on non-existent income and that the CBDT’s powers under Section 119(2)(b) include granting relief in extraordinary situations to prevent injustice. The Court quashed the CBDT’s order, directing reassessment based on actual income and allowing the petitioner’s writ. (W.P. No. 23255 of 2011 & Batch, dt. 31/01/2025) (AY. 2002 -03 , 2007 -08 , 2009 -10)