- 1 - HC-KAR NC: 2025:KHC:37633 WP No. 22235 of 2023 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 22235 OF 2023 (T-IT) BETWEEN: PRASANNA JAIKRISHNAMOORTHY I LAND EXPRESSIONS FLAT, NO. 408, ANANTHNAGAR PHASE 2, KAMMASANDRA VILLAGE, ANEKAL TALUK, BENGALURU - 560 100. (PAN NO. APDPJ5900J) …PETITIONER (BY SRI. BHARATH JANARTHANAN, ADVOCATE) AND: 1. ASSESSMENT UNIT - NATIONAL FACELESS ASSESSMENT CENTRE REP. BY ADDITIONAL/JOINT/DEPUTY/ ASSISTANT COMMISSIONER OF INCOME -TAX, INCOME-TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003. 2. THE INCOME TAX OFFICER -WARD -1, O/O THE INCOME TAX OFFICER – WARD 1, INCOME-TAX DEPARTMENT, NO. 2, FIRST FLOOR, JAWAHARLAL NEHRU ROAD, Digitally signed by NAGAVENI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:37633 WP No. 22235 of 2023 TIRUVALLUR - 602 001. TAMILNADU. 3. INCOME TAX OFFICER WARD 5(3)(4), BMTC BUILDING 80 FEET ROAD, NEAR KHB GAMES VILLAGE 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 A) QUASH THE IMPUGNED NOTICE UNDER SECTION 148A(B) OF THE ACT BEARING DIN NO. ITBA/AST/F/148A(SCN)/2021- 22/1041268118(1) DATED 22/03/2022 ISSUED BY R2 HEREIN FOR THE AY 2018-19 AND MARKED AS ANNEXURE-A AND ETC., THIS PETITION, COMING ON FOR ORDERS, 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: "(a) Issue a writ of Certiorari or similar writ, order or direction to quash the impugned notice under section 148A(b) of the Act bearing DIN No. ITBA/AST/F/148A(SCN)/2021-22/1041268118(1) - 3 - HC-KAR NC: 2025:KHC:37633 WP No. 22235 of 2023 dated 22.03.2022 Issued by Respondent No.2 herein for the AY 2018-19 and marked as ANNEXURE 'A'; (b) Issue a writ of Certiorari or similar writ, order or direction to quash the impugned order under Section 148A(d) of the Act bearing DIN No. ITBA/AST/F/148A/2021-22/1042286882(1) dated 31.03.2022 passed by Respondent No.2 herein for the dated AY 2018-19 and marked as ANNEXURE 'B'; (c) Issue a writ of Certiorari or similar writ, order or direction to quash the consequential impugned notice under Section 148 of the Act bearing DIN No. ITBA/AST/S/148_1/2021- 22/1042358841(1) dated 31.03.2022 issued by Respondent No.2 herein for the AY 2018-19 and marked as ANNEXURE 'C'; (d) issue a writ of Certiorari or similar writ, order or direction to quash the impugned ex-parte Assessment order under Section 147 r.w.s 144 r.w.s. 144B of the Act bearing DIN No. ITBA/AST/S/147/2022-23/1050580582(1) dated 10.03.2023 along with computation sheet bearing DIN No. ITBA/S/183/2022-23/1050580713(1) dated 10.03.20233 and notice of demand under section 156 of the Act dated 10.03.2023 bearing DIN No. ITBA/AST/S/156/2022-23/1050580696(1) dated 10.03.2023 collectively issued by Respondent No.1 for the AY 2018-19 and enclosed as ANNEXURE 'D'-COLLY; (e) Issue a writ of Certiorari or similar writ, order or direction to quash the impugned penalty notice under section 274 r.w.s 272A(1)(d) of the Act bearing DIN No. ITBA /PNL/S/272A(1)(d)_FL/2022 - 23/1050576458(1) dated 10.03.2023 issued by Respondent No.1 for the AY 2018-19 and enclosed as ANNEXURE 'E'; - 4 - HC-KAR NC: 2025:KHC:37633 WP No. 22235 of 2023 (f) Issue a writ of Certiorari or similar writ, order or direction to quash the impugned Penalty notice under section 274 r.w.s 270A of the Act bearing DIN No. ITBA/PNL/S/270A/2022- 23/1050580655(1) dated 10.03.2023 issued by Respondent No.1 for the AY 2018-19 and enclosed as ANNEXURE 'F'; (g) Issue a writ of Certiorari or similar writ, order or direction to quash the impugned order under section 272A(1)(d) of the Act bearing DIN No.ITBA/PNL/F/272A(1)(d)/2023- 24/1055876605(1) dated 06.09.2023 along with computation sheet bearing DIN No. 2023201840413326705T dated 06.09.2023 and notice of demand under section 156 of the Act dated 06.09.2023 bearing DIN No. ITBA/PNL/S/156/2023-24/1055876543(1), collectively passed by Respondent No.1 for the AY 2018-19 and enclosed as ANNEXURE 'G'- COLLY; (h) issue a writ of Certiorari or similar writ, order or direction to quash the impugned order under section 270A of the Act bearing DIN No. ITBA/PNL/F/270A/2023-24/1055963018(1) dated 12.09.2023 along with computation sheet bearing DIN No. 2023201840413440606T dated 12.09.2023 and notice of demand under section 156 of the Act dated 12.09.2023 bearing DIN No. ITBA/PNL/S/156/2023-24/1055963063(1), collectively passed by Respondent No.1 for the AY 2018-19 and enclosed as ANNEXURE 'H'- COLLY; and / or (i) issue any other writ, order or direction as deemed fit and appropriate by this Hon'ble Court." - 5 - HC-KAR NC: 2025:KHC:37633 WP No. 22235 of 2023 2. Heard Sri Bharath Janarthanan, learned counsel for the petitioner and Sri M. Dilip, 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 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned show cause notices 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. - 6 - HC-KAR NC: 2025:KHC:37633 WP No. 22235 of 2023 (iii) With the aforesaid liberty and to the aforesaid extent, the petition is allowed. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered and I.A.No.1/2024 seeking impleadment would be considered, in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE BSV List No.: 1 Sl No.: 210 CT: BHK