- 1 - HC-KAR NC: 2025:KHC:39686 WP No. 2356 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 2356 OF 2024 (T-IT) BETWEEN: SRI PRAKASH SASTRY MADUGANDUR S/O M.L.SASTRY AGED ABOUT 48 YEARS 344, 16TH CROSS, 18TH MAIN ROAD J.P.NAGAR 5 PHASE BENGALURU – 560 078 (REPRESENTED BY GPA HOLDER SHRI DR.A.SREENIVASAN S/O LATE T.K.ANANTHANARAYAN AGED ABOUT 80 YEARS) …PETITIONER (BY SRI. CHIDANANDA URS B.G., ADVOCATE) AND: 1. THE INCOME TAX OFFICER OFFICE OF THE INCOME TAX OFFICER WARD 3(2)(1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU – 560 095. 2. NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39686 WP No. 2356 of 2024 GOVERNMENT OF INDIA MINISTRY OF FINANCE, NEW DELHI - 110 001. 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX OFFICE OF THE INCOME TAX DEPARTMENT C.R.BUILDING NO.1 QUEENS ROAD BENGALURU – 560 001. …RESPONDENTS (BY SRI M.DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO SET ASIDE THE NOTICE UNDER SECTION 148A (b) IN DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2021-22/1041117766(1) DTD 21.03.2021 ISSUED BY R1 WHICH IS HEREWITH ENCLOSED AS ANNEXURE-B AS TIME BARRED AND NOT SERVED IN ACCORDANCE WITH LAW; SET ASIDE THE ORDER PASSED UNDER SECTION 148A(d) OF THE ACT IN DIN AND NOTICE NO. ITBA/AST/F/148A/2021-22/1042363595(1) DTD 31.03.2022 BY R1 FOR THE ASSESSMENT YEAR 2018-19 WHICH IS HEREWITH ENCLOSED AS ANNEXURE-C DOES NOT BEAR TIME STAMP OR DIGITAL SIGNATURE AS TIME BARRED AND WITHOUT JURISDICTION UNDER FACELESS ASSESSMENT SCHEME; SET ASIDE THE ASSESSMENT ORDER PASSED BY R2 DTD 21.03.2023 IN DIN NO. ITBA/AST/S/147/22- 23/1051090040(1) UNDER SECTION 147 READ WITH SECTION 144 AND 144B OF THE INCOME TAX ACT WHICH IS HEREWITH ENCLOSED AS ANNEXURE-D; SET ASIDE THE RECOVERY/ - 3 - HC-KAR NC: 2025:KHC:39686 WP No. 2356 of 2024 DEMAND NOTICES UNDER SECTION 156 OF THE ACT WHICH NOTICES IN DIN AND NOTICE NO. ITBA/PNL/S/156/2023- 24/1056486827(1) DTD 25.09.2023 IS HEREWITH ENCLOSED AS ANNEXURE-E. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of DIN and notices bearing No.ITBA/AST/F/148A(SCN)/2021-22/1041117766(1) dated 21.03.2021, ITBA/AST/F/148A/2021-22/1042363595(1) dated 31.03.2022, ITBA/PNL/S/156/2023-24/1056486827(1) dated 25.09.2023 and order No.ITBA/AST/S/147/2022- 23/1051090040(1) dated 21.03.2023 passed by the respondents – Revenue under Sections 147 r/w. 144 and 144B, 148, 148A(b), 148A(d) and 156 of the Income Tax Act, 1961. 2. Heard Sri Chidananda Urs B.G., learned counsel for the petitioner and Sri M. Dilip, learned counsel for the respondents. - 4 - HC-KAR NC: 2025:KHC:39686 WP No. 2356 of 2024 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 DIN and notices bearing No. ITBA/AST/F/148A(SCN)/2021-22/1041117766(1) dated 21.03.2021, ITBA/AST/F/148A/2021- 22/1042363595(1) dated 31.03.2022, ITBA/PNL/S/156/2023-24/1056486827(1) dated 25.09.2023 issued by the jurisdictional Assessing Officer outside the scope of Section 151A 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. - 5 - HC-KAR NC: 2025:KHC:39686 WP No. 2356 of 2024 (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 in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 2 Sl No.: 4