- 1 - HC-KAR NC: 2025:KHC:39331 WP No. 32612 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. 32612 OF 2024 (T-IT) BETWEEN: SOMASHEKAR MAMATHA WIFE OF SHRI. SURESH K, AGED ABOUT 49 YEARS, 1 1 SRI RANGANATHA NILAYA, 2ND CROSS, BHARMAPPA NAGAR, SHIVAMOGGA- 577 201. …PETITIONER (BY SRI. RAVI SHANKAR S V., ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD-1 AND TPS, SHIMOGA, IT OFFICE, SHIMOGA, NO. 75, 100FT ROAD, GOPAL GOWDA EXTEN., SHIVAMOGA - 577 201 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU - 1, BMTC BUILDING, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39331 WP No. 32612 of 2024 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095 3. NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110003 …RESPONDENTS (BY SRI. M.DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE UNSIGNED SANCTION DTD 25.3.2024 ACCORDED U/S 151 OF THE ACT FOR THE AY 2020-21 BY THE R-2 BEARING DIN AND NOTICE NO. ITBA/AST/S/118/2023-24/1063333960(1) HEREIN MARKED AS ANNX-AQUASHING THE NOTICE DTD 29.03.2024 ISSUED U/S 148 OF THE ACT FOR THE AY2020-21 BY THE R-1 BEARING DIN AND NOTICE NO. ITBA/AST/S/148 1/2023- 24/1063603180(1) HEREIN MARKED AS ANNX-A1. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39331 WP No. 32612 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “a) Issue a writ of Certiorari or direction in the nature of dated 25.03.2024 accorded under section 151 of the a writ of certiorari quashing the unsigned sanction Act for the assessment year 2020-21 by the Respondent No. 2 bearing DIN & Notice No. ITBA/AST/S/118/2023-24/1063333960(1) herein marked as Annexure - A. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 29.03.2024 issued under section 148 of the Act for the assessment year 2020- 21 by the Respondent No. 1 bearing DIN & Notice No. ITBA/AST/S/148_1/2023- 24/1063603180(1) herein marked as Annexure - A1. c) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Shri Ravishankar S.V., learned counsel appearing for the petitioner and Shri M. Dilip, learned counsel appearing for the respondents. - 4 - HC-KAR NC: 2025:KHC:39331 WP No. 32612 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 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. - 5 - HC-KAR NC: 2025:KHC:39331 WP No. 32612 of 2024 (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 JY List No.: 2 Sl No.: 59