- 1 - HC-KAR NC: 2025:KHC:36411 WP No. 12548 of 2023 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 11TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 12548 OF 2023 (T-IT) BETWEEN: BISANAHALLI NYATHAPPA SRINIVASA REDDY AGED ABOUT 64 YEARS, S/O LATE SRI. NYATHAPPA, NO.352, 1ST SECTOR, 29TH MAIN, 10TH CROSS, HSR LAYOUT, BANGALORE - 560 102. …PETITIONER (BY SRI. MADHUSUDHAN U.A, ADVOCATE) AND: 1. CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI - 110 002 REPRESENTED HEREIN BY ITS CHAIRPERSON. 2. ASSESSMENT UNIT/ INCOME TAX OFFICER NATIONAL FACELESS ASSESSMENT CENTRE, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWARLAL NEHRU STADIUM, DELHI - 110 003. 3. THE INCOME TAX OFFICER WARD 4(3) (2) BMTC BUILDING, 80 FEET ROAD, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:36411 WP No. 12548 of 2023 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560 095. 4. THE PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU-2, CENTRAL REVENUE BUILDING, QUEENS ROAD, BANGALORE - 560 001. …RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE ASSESSMENT ORDER DATED 26/05/2023 PASSED UNDER SECTION 147 RWS 144B OF THE ACT FOR THE ASSESSMENT YEAR 2016-17 BY THE R2 BEARING DIN NO. ITBA/AST/S/147/2023-24/1053206771(1) HEREIN MARKED AS ANNEXURE -A1 AND ETC., 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 - Assessee is before this Court seeking quashment of DIN and notices bearing No.ITBA/AST/S/156/2023-24/1053206881(1) dated 26.05.2023, ITBA/PNL/S/271(1)(c)/2023-24/1053206915(1) dated 26.05.2023, ITBA/COM/F/17/2022-23/1043287641(1) - 3 - HC-KAR NC: 2025:KHC:36411 WP No. 12548 of 2023 dated01.06.2022, ITBA/AST/M/148_1/2022-23/1044314958(1) dated 29.07.2022, instruction bearing No.1/2022 dated 11.05.2022, computation sheet bearing No.ITBA/AST/S/114/2023-24/1053206831(1) dated 26.05.2023 and order No.ITBA/AST/S/147/2023- 24/1053206771(1) dated 26.05.2023, ITBA/COM/F/17/2022- 23/1044290673(1) dated 29.07.2022, passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Madhusudhan U.A., learned counsel for the petitioner and Sri E.I.Sanmathi, learned counsel for the respondents. 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 - 4 - HC-KAR NC: 2025:KHC:36411 WP No. 12548 of 2023 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/S/156/2023-24/1053206881(1) dated 26.05.2023, ITBA/PNL/S/271(1)(c)/2023- 24/1053206915(1) dated 26.05.2023, ITBA/COM/F/17/2022-23/1043287641(1) dated01.06.2022, ITBA/AST/M/148_1/2022- 23/1044314958(1) dated 29.07.2022, 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. (iii) With the aforesaid liberty and to the aforesaid extent, the petition is allowed. - 5 - HC-KAR NC: 2025:KHC:36411 WP No. 12548 of 2023 (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 SS/nvj List No.: 1 Sl No.: 8 CT: BHK