- 1 - HC-KAR NC: 2025:KHC:40710 WP No. 2452 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 14TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 2452 OF 2025 (T-IT) BETWEEN: KEMPANNA ROOPA, W/O M. N. UMASHANKAR, AGED ABOUT 43 YEARS, PAN NO. BZUPR 0748 G RESIDING AT: NO.24/1A, MATTAHALLI MAIN ROAD, NARASIPURA, DASANAPURA HOBLI, BANGALORE, KARNATAKA - 562 123. …PETITIONER (BY SRI. RAJEEV CHANNAPPA NULVI, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD 6(2) (1), BANGALORE BMTC BUILDING, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORMANGALA, BENGALURU - 560 095. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX, RANGE 1, BANGALORE, BMTC BUILDING, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORMANGALA, BENGALURU - 560 095. 3. THE ASSESSMENT UNIT, INCOME TAX DEPARTMENT, THE NATIONAL FACELESS ASSESSMENT CENTRE, NORTH BLOCK, NEW DELHI, DELHI - 110 001. …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:40710 WP No. 2452 of 2025 THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE IMPUGNED ASSESSMENT ORDER DATED 25.01.2024, UNDER SEC. 147 R.W.S 144 R.W.S 144B OF THE INCOME TAX ACT, 1961, BEARING DIN AND NOTICE NO ITBA/AST/S/147/2023-24/1060100705(1) ALONG WITH COMPUTATION SHEET DATED 25.01.2024, BEARING DIN AND NOTICE NO. ITBA/AST/S/319/2023-24/1060100788(1) AND NOTICE OF DEMAND DATED 25.01.2024, UNDER SEC. 156 OF THE INCOME TAX ACT, 1961, BEARING DIN AND NOTICE NO. ITBA/AST/S/156/2023-24/1060100808(1), PASSED BY THE RESPONDENT AUTHORITY NO.3 THE ASSESSMENT UNIT, INCOME TAX DEPARTMENT, PERTAINING TO ASSESSMENT YEAR 2019-20, VIDE ANNEXURE A, A-1 AND A-2 RESPECTIVELY AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN 'B' GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks for the following reliefs: "A. To issue a WRIT of CERTIORARI, quashing the impugned Assessment Order Dated: 25/01/2024, under Sec. 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961, bearing DIN & Notice No: ITBA/AST/S/147/2023-24/1060100705(1) along with Computation Sheet Dated: 25/01/2024, bearing Notice DIN & No: ITBA/AST/S/319/2023-24/1060100788(1) and Notice of Demand Dated: 25/01/2024, under Sec. 156 of the Income Tax Act, 1961, bearing DIN & Notice No: ITBA/AST/S/156/2023-24/1060100808(1), passed by the Respondent Authority No.3 - The Assessment Unit, Income Tax Department, pertaining - 3 - HC-KAR NC: 2025:KHC:40710 WP No. 2452 of 2025 to Assessment Year 2019-20, wide Annexure A, A-1 & A-2 respectively; and B. To issue a WRIT of CERTIORARI, quashing the impugned Penalty Order Dated: 14/06/2024, under Sec. 270A of the Income Tax Act, 1961, bearing DIN & Notice No: ITBA/PNL/F/2704/2024- 25/1065688525(1) along with Computation Sheet Dated: 14/06/2024, bearing DIN & Notice No: ITBA/PNL/S/270A/2023-24/1060100885(1) and Notice of Demand Dated: 14/06/2024, under Sec. 156 of the Income Tax Act, 1961, bearing DIN & Notice No: passed by the ITBA/PNL/S/156/2024- 25/1065688466(1); Respondent Authority No.3 - The Assessment Unit, Income Tax Department, pertaining to Assessment Year 2019-20, vide Annexure: B, B-1 & B-2 respectively; and C. To issue a WRIT of CERTIORARI, quashing the impugned Penalty Order Dated: 14/06/2024, under Sec. 271AAC(1) of the Income Tax Act, 1961, bearing DIN & Notice No: ITBA/PNL/F/271AAC(1)/2024- 25/1065644351(1) along with Computation Sheet Dated: 14/06/2024, bearing DIN & Notice No: ITBA/PNL/S/271AAC(1)/2023-24/1060100887(1) and Notice of Demand Dated: 14/06/2024, under Sec. 156 of the Income Tax Act, 1961, bearing DIN & Notice No: ITBA/PNL/S/156/2024-25/1065642162(1); passed by the Respondent Authority No. 3 - The Assessment Unit, Income Tax Department, pertaining to - 4 - HC-KAR NC: 2025:KHC:40710 WP No. 2452 of 2025 Assessment Year 2019-20, vide Annexure: C, C1 & C-2 respectively,; and D. To Issue a WRIT of CERTIORARI, quashing the impugned Notice Dated: 21/03/2023, bearing DIN & Notice No: ITBA/AST/S/148_1/2022- 23/1051031470(1), under Sec. 148 of the Income Tax Act, 1961, issued by the Income Tax Officer, Ward 6(2)(1), Bangalore, in respect of the petitioner, pertaining to Assessment Year 2019-20, Vide ANNEXURE - F, and E. To issue a WRIT of CERTIORARI, quashing the impugned order dated: 21/03/2023, vide DIN No. ITBA/AST/F/148A/2022-23/1051030727(1), under Sec. 148A(d) of the Income Tax Act, 1961, passed by the Income Tax Officer, Ward 6(2)(1), Bangalore, in respect of the petitioner, pertaining to Assessment Year 2019-20, Vide ANNEXURE - E, and F. To issue a WRIT of CERTIORARI, quashing the impugned Show Cause Notice dated: 02/02/2023, vide DIN No. ITBA/AST/F/148A(SCN)/2022- 23/1049368560(1), and another Show Cause Notice dated: 10/03/2023, vide DIN No. under Sec. ITBA/AST/F/148A(SCN)/2022-23/1050612828(1), 148A(b) of the Income Tax Act, issued by the Income Tax Officer, Ward 6(2)(1), Bangalore, in respect of the petitioner, pertaining to Assessment Year 2019-20, Vide ANNEXURE - D & D-1 respectively. - 5 - HC-KAR NC: 2025:KHC:40710 WP No. 2452 of 2025 G. To pass any such other Writ, Order or Direction as this Hon'ble court might deem fit to be issued in the fact and circumstances of the case in the interest of justice and equity." 2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitioner invited my attention to the order of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order. 4. Per contra, learned counsel for the respondents submits that there is no merit in the petition and that the same is liable to be dismissed. 5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the decision of a Co-ordinate Bench of this Court in the case of - 6 - HC-KAR NC: 2025:KHC:40710 WP No. 2452 of 2025 Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under: "13. I, therefore, pass the following: O R D E R (i) The impugned show cause notices 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 these cases would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of these petitions would become necessary." 6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of - 7 - HC-KAR NC: 2025:KHC:40710 WP No. 2452 of 2025 co-ordinate Bench of this Court in Ramachandra Reddy's case (supra). 7. In the result, I pass the following: ORDER (i) The petition is allowed and disposed of in terms of the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025. (ii) The impugned show cause notices and consequential orders, notices etc., at Annexures-A, A1, A2, B, B1, B2, C, C1, C2, F, E, D and D1 dated 25.01.2024, 25.1.2024, 25.01.2024, 14.06.2024, 14.06.2024, 14.06.2024, 14.06.2024, 14.06.2024, 14.06.2024, 21.03.2022, 21.03.2023, 02.02.2023 and 10.03.2023, respectively are hereby quashed. (iii) Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, subsequent to disposal of the matters pending before the Apex - 8 - HC-KAR NC: 2025:KHC:40710 WP No. 2452 of 2025 Court and all rival contentions between the parties in this regard are kept open and no opinion is expressed on the same. Sd/- (S.R.KRISHNA KUMAR) JUDGE BMC List No.: 2 Sl No.: 83