- 1 - HC-KAR NC: 2025:KHC:39248 WP No. 29068 of 2025 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. 29068 OF 2025 (T-IT) BETWEEN: 1. PAPA REDDY NARAYANA REDDY SON OF MR. PAPAREDDY AGED ABOUT 54 YEARS RESIDING AT NO.59, YALLAMMA DEVI TEMPLE STREET, KAMBLIPURA, MAYASANDRA, ANEKAL, BANGALORE - 562 107 …PETITIONER (BY SRI. SANDEEP HUILGOL, ADVOCATE) AND: 1. THE ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT, 2ND FLOOR, JAWAHARLAL NEHRU STADIUM NEW DELHI - 110 003 2. THE INCOME TAX OFFICER, WARD 1(6), SALEM, INCOME TAX OFFICE, NO. 3, GANDHI ROAD, SALEM - 636 007 3. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39248 WP No. 29068 of 2025 TAMIL NADU AND PUDUCHERRY, 121, NUNGAMBAKKAM HIGH ROAD, CHENNAI - 600 034 4. COMMISSIONER OF INCOME-TAX (APPEALS), NATIONAL FACELESS APPEAL CENTRE, INCOME TAX DEPARTMENT, ROOM NO. 245-A, NORTH BLOCK, NEW DELHI - 110 001 5. THE DEPUTY COMMISSIONER OF INCOME TAX 4(3) (1), BENGALURU BMTC BHAVAN, 80 FEET ROAD, NEAR SONY WORLD SIGNAL, KORAMANGALA, BANGALORE - 560 034. 6. PRINCIPAL COMMISSIONER OF INCOME-TAX KARNATAKA AND GOA REGION, BANGALORE, C.R. BUILDING, NO.1, QUEEN'S ROAD, BANGALORE - 560 001 …RESPONDENTS (BY SRI. SUSHAL TIWARI, ADVOCATE) THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO I. QUASHING THE IMPUGNED ASSESSMENT ORDER DATED 09.03.2024 BEARING DIN NO. ITBA/AST/S/147/2023-24/10622318259(1) PASSED BY THE 1ST RESPONDENT UNDER SECTION 147 READ WITH SECTION 144 OF THE INCOME-TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2016-17 (ANNEXURE A) AND ETC. - 3 - HC-KAR NC: 2025:KHC:39248 WP No. 29068 of 2025 THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court, seeking the following prayer: “i. Quashing the impugned assessment order dated 09.03.2024 bearing DIN No. ITBA/AST/S/147/2023-24/10622318259(1) passed by the 1st Respondent under Section 147 read with Section 144 of the Income-tax Act, 1961 for the assessment year 2016-17 (Annexure 'A'). ii. Quashing the impugned computation sheet dated 09.03.2024 bearing DIN and Document No. ITBA/AST/114/2023-24/1062318292(1) issued by the 1st Respondent for the assessment year 2016- 17 (Annexure 'A-1'); iii. Quashing the impugned demand notice dated 09.03.2024 bearing DIN and Notice No. ITBA/AST/S/156/2023-24/1062318374(1) issued by the 1st Respondent under Section 156 of the Income-tax Act, 1961 for the assessment year 2016-17 (Annexure 'A-2'); iv. Quashing the impugned Notice for penalty dated 09.03.2024 bearing DIN No. ITBA/AST/S/156/2023-24/1062318374(1) issued by the 1st Respondent under Section 156 of the Income-tax Act, 1961 for the assessment year 2016-17 (Annexure 'A-2'); iv. Quashing the impugned Notice for penalty dated 09.03.2024 bearing DIN No. ITBA/PNL/S/271(1)(c)/2023-24/10623188348(1) issued by the 1st Respondent under Section 274 read with Section 271(1)(c) of the Income-tax Act, - 4 - HC-KAR NC: 2025:KHC:39248 WP No. 29068 of 2025 1961 for the assessment year 2016-17 (Annexure 'Q') v. Quashing the impugned Notice dated 31.03.2023 bearing DIN and Notice No. ITBA/AST/S/148_1/2022- 23/1051825175(1) issued by the 2nd Respondent under Section 148 of the Income-tax Act, 1961, for assessment year 2016-17 (Annexure 'F') vi. Quashing the impugned order dated 31.03.2023 bearing DIN and Notice No. ITBA/AST/F/148A/2022-23/1051818425(1) passed by the 2nd Respondent under Section 148A(d) of the Income-tax Act, 1961, for the assessment year 2016-17 (Annexure 'F-1') vii. Quashing the impugned Letter of Recovery dated 09.10.2024 bearing DIN and Letter No. ITBA/COM/F/17/2024-25/1069550474(1) issued by the 2nd Respondent under the relevant provisions of the Income-tax Act, 1961 for the Assessment Year 2016-17 (Annexure 'S'); viii. Declare that, without prejudice and in any event, the jurisdictional Assessing Officer is the 5th Respondent and not the 2nd Respondent. ix. Pass such other or further order as this Hon'ble Court may deem fit in the facts and circumstances of the case, and in the interests of justice and equity. 2. Heard Sri Sandeep Huilgol, learned counsel for the petitioner and Sri Sushal Tiwari, learned counsel for the respondents. - 5 - HC-KAR NC: 2025:KHC:39248 WP No. 29068 of 2025 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 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. - 6 - HC-KAR NC: 2025:KHC:39248 WP No. 29068 of 2025 (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 SJK CT-SG List No.: 5 Sl No.: 34