- 1 - HC-KAR NC: 2025:KHC:40855 WP No. 30819 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. 30819 OF 2025 (T-IT) BETWEEN: SANJAY LALCHAND MAHTANI AN INDIVIDUAL, SON OF MR. LALCHAND MAHTANI, AGED ABOUT 57 YEARS, RESIDING AT NO. 213, EMBASSY WOODS, 6A CUNNINGHAM ROAD, BANGALORE - 560 052 EMAIL: srivatsalaw@gmail.com PHONE: +91 89714 70774 …PETITIONER (BY SRI. PRADYUMNA HEJIB, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 4(3)(1), BANGALORE KORAMANGALA, BENGALURU - 560 095 2. THE ASSESSMENT UNIT, INCOME TAX DEPARTMENT NATIONAL FACELESS ASSESSMENT CENTRE MINISTRY OF FINANCE, NEW DELHI - 110 001 3. THE COMMISSIONER OF INCOME TAX (APPEALS), NATIONAL FACELESS APPEALS CENTRE MINISTRY OF FINANCE, NEW DELHI - 110 001 Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:40855 WP No. 30819 of 2025 4. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU - 1 80 FT. ROAD, BMTC BUILDING, KORAMANGALA, BENGALURU - 560 095 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT IN THE NATURE OF CERTIORARI OR ANY OTHER WRIT TO QUASH NOTICE ISSUED UNDER SECTION UNDER 148A(B) OF THE ACT BEARING DIN ITBA/AST/F/148A(SCN)/2021-22/1040758856(1) DATED 15.03.2022 ISSUED BY THE FIRST RESPONDENT (ANNEXURE -A) AND ETC., THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks for the following reliefs: (a) Issue a writ in the nature of certiorari or any other writ to quash notice issued under Section under 148A(b) of the Act bearing DIN ITBA /AST/F/148A(SCN)/2021- 22/1040758856(1) dated 15.03.2022 issued by the First Respondent (Annexure A); (b) Issue a writ in the nature of certiorari or any other writ to quash the notice issued by the First Respondent under Section 148A(d) of the Act bearing DIN ITBA /AST/F/148A(SCN)/2024-25/1067787838(1) dated 31.03.2022 (Annexure - B); (c) Issue a writ in the nature of certiorari or any other writ to quash notice issued by the First Respondent under - 3 - HC-KAR NC: 2025:KHC:40855 WP No. 30819 of 2025 Section 148 of the Act bearing DIN ITBA/AST/S/148_1/2021 22/1042372768(1) dated 31.03.2022 (Annexure - C); (d) Issue a writ in the nature of certiorari or any other writ to quash notice issued by the Second Respondent under Section 143(2), read with Section 147 of the Act, dated 07.10.2022, bearing DIN No. ITBA/AST/F/143(2)_5/2022-23/1046206927(1) (Annexure - D); (e) Issue a writ in the nature of certiorari or any other writ to quash notice was issued by the Second Respondent under Section 142(1) dated 30.12.2022 bearing DIN ITBA/AST/F/142(1)/2022- 23/1048370582(1) (Annexure - E); (f) Issue a writ in the nature of certiorari or any other writ to quash Notice issued under Section 147 of the Act by the Second Respondent bearing. DIN ITBA/AST/F/147(SCN)/2022-23/1050469147(1) dated 06.03.2023 (Annexure - F); (g) Issue a writ in the nature of certiorari or any other writ to quash Assessment Order issued by the Second Respondent under Section 147, read with 144B of the Act, dated 21.03.2023 bearing DIN ITBA/AST/S/147/2022-23/1051106074(1) (Апnexure - G); (h) Issue a writ in the nature of certiorari or any other writ to quash Computation sheet issued by the Second - 4 - HC-KAR NC: 2025:KHC:40855 WP No. 30819 of 2025 Respondent bearing DIN ITBA/AST/S/183/2022- 23/1051106598(1) dated 21.03.2023 (Annexure - H); (j) Issue a writ in the nature of certiorari or any other writ to quash order passed by the Second Respondent under Section 156 of the Act bearing No. ITBA/AST/S/156/2022-23/1051106704(1) (ANNEXURE-J); (k) Issue a writ in the nature of certiorari or any other writ to quash order passed by the Fourth Respondent bearing DIN ITBA/COM/F/17/2025-26/1078744511(1) dated 22.07.2025 (ANNEXURE-K); (l) Grant such other order or direction as deemed fit in the facts and circumstances of the case in the interest of justice." 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 - - 5 - HC-KAR NC: 2025:KHC:40855 WP No. 30819 of 2025 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 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. - 6 - HC-KAR NC: 2025:KHC:40855 WP No. 30819 of 2025 (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 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 - 7 - HC-KAR NC: 2025:KHC:40855 WP No. 30819 of 2025 to K dated 15.03.2022, 31.03.2022, 31.03.2022, 07.10.2022, 30.12.2022, 06.03.2023, 21.03.2023, 21.03.2023, 21.03.2023 and 22.07.2025 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 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.: 72