- 1 - HC-KAR NC: 2025:KHC:38227 WP No. 9353 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28TH DAY OF AUGUST, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO.9353 OF 2024 (T-IT) BETWEEN: M/S MYSORE DISTRICT JUDICIAL EMPLOYEES CREDIT CO-OPERATIVE SOCIETY LIMITED., REPRESENTED BY ITS PRESIDENT SRI. M. V. SHESHADRI, AGED ABOUT 56 YEARS S/O SRI. M. VISWESHWARIAH MYSORE AND CHAMARAJANAGAR DISTRICT JUDICIAL EMPLOYEES CREDIT CO-OPERATIVE SOCIETY LIMITED OFFICE AT MYSORE LAW COURT PREMISES CHMARAJPURAM, MYSORE PIN CODE: 570 005 PAN: AACAM 7977 M CO-OPERATIVE SOCIETY ACT, 1956 …PETITIONER (BY SRI. ANNAMALAI S., ADVOCATE) AND: 1. ASSESSMENT UNIT INCOME TAX DEPARTMENT REP. BY ADDITIONAL/JOINT/DEPUTY / ASSISTANT Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:38227 WP No. 9353 of 2024 COMMISSIOENR OF INCOME-TAX/INCOME TAX OFFICER, INCOME TAX DEPARTMENT MINISTRY OF FINANCE ROOM NO.401, 2ND FLOOR, E-RAMP JAWAHARLAL NEHRU STADIUM DELHI - 110 003 2. THE ASSISTANT COMMISSIONER OF INCOME – TAX, CIRCLE 1(1) & TPS MYSORE, ROOM NO.113, 1ST FLOOR, AYAKAR BHAVAN REAC, MYSORE. PIN CODE: 570 008 3. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KARNATAKA & GOA C. R. BUILDING, QUEENS ROAD, BENGALURU - 560 001 …RESPONDENTS (BY SRI. E. I. SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF QUASHING THE ASSESSMENT ORDER PASSED UNDER SECTION 147 RWS 144B OF THE ACT DATED 28/02/2024 BEARING DIN NO.ITBA/AST/S/147/2023-24/1061691231(1) ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2015-16 HEREIN MARKED AS ANNEXURE-A1 AND ETC THIS PETITION COMING ON FOR PRELIMINARY HEARING THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:38227 WP No. 9353 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayer: “i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the assessment order passed under section 147 rws 144B of the Act dated 28/02/2024 bearing DIN No. ITBA/AST/S/147/2023-24/1061691231(1) issued by the Respondent No. 1 for the assessment year 2015-16 herein marked as Annexure - A1. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 28/02/2024 bearing DIN & Document No. ITBA/AST/S/115/2023-24/1061691370(1) issued by the Respondent No. 1 for the assessment year 2015-16 herein marked as Annexure - A2. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the demand notice dated 28/02/2024 issued under section 156 of the Act bearing DIN & Notice No. ITBA/AST/S/156/2023-24/1061691281(1) issued by the Respondent no. 1 for the assessment year 2015-16 herein marked as Annexure АЗ. iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 28/02/2024 issued under section 274 rws 271(1)(c) of the Act bearing DIN No. ITBA/PNL/S/271(1)(c)/2023-24/1061691410(1) issued by the Respondent No. 1 for the assessment year 2015-16 herein marked as Annexure A4. v) Issue a writ of Certiorari or direction in the nature of a writ of notice dated certiorari quashing the penalty 28/02/2024 issued under section 274 rws 271(1)(b) of the Act bearing DIN & Notice No. - 4 - HC-KAR NC: 2025:KHC:38227 WP No. 9353 of 2024 ITBA/PNL/F/271(1)(b)/2023-24/1061691409(1) issued by the Respondent No. 1 for the assessment year 2015-16 herein marked as Annexure A5. vi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 28/02/2024 issued under section 274 rws 271A of the Act bearing DIN No. ITBA/PNL/S/271A/2023-24/1061691407(1) issued by the Respondent No. 1 for the assessment year 2015-16 herein marked as Annexure A6. vii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 28/02/2024 issued under section 274 rws 271B of the Act bearing DIN No. ITBA/PNL/S/271B/2023-24/1061691408(1) issued by the Respondent No. 1 for the assessment year 2015-16 herein marked as Annexure A7. viii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 28/02/2024 issued under section 274 rws 271F of the Act bearing DIN No. ITBA/PNL/S/271F/2023-24/1061691426(1) issued by the Respondent No. 1 for the assessment year 2015-16 herein marked as Annexure A8. ix) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 23/03/2022 issued under section 148A(b) of the Act bearing DIN & Notice No. ITBA/AST/F/148A(SCN)/2021-22/1041313880(1) issued by the Respondent No. 2 for the assessment year 2015-16 herein marked as Annexure - B1. x) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed under Section 148A(d) of the Act dated 04/04/2022 bearing DIN & Notice No. ITBA/AST/F/148A/2022- 23/1042486771(1) issued by the Respondent No. 2 for the assessment year 2015-16 herein marked as Annexure - B2. - 5 - HC-KAR NC: 2025:KHC:38227 WP No. 9353 of 2024 xi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 04/04/2022 issued under section 148 of the Act bearing DIN & Notice No. ITBA/AST/S/148_1/2022- 23/1042486965(1) issued by the Respondent No. 2 for the assessment year 2015-16 herein marked as Annexure - вз. xii) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri E.I.Sanmathi, learned counsel for the respondents. 3. The grounds projected in the subject petition in support of the prayer quoted supra are identical to the ones considered by this Court in W.P.No.28182/2024 and connected matters, disposed on 28.08.2025. 4. In the light of the issue being similar and the reasons rendered therein becomes applicable to the case at hand, the petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned show cause notice issued by the jurisdictional Assessing Officer outside the scope of - 6 - HC-KAR NC: 2025:KHC:38227 WP No. 9353 of 2024 Section 151-A of the Act stand obliterated. All further proceedings initiated thereto, challenged in this petition would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive the petition in the event, the Apex Court would hold in favour of the Revenue in the matter pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petition is allowed. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered and I.A.No.1/2024 would be considered, in the event revival of this petition becomes necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 361