- 1 - HC-KAR NC: 2025:KHC:38145 WP No. 4179 of 2024 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. 4179 OF 2024 (T-IT) BETWEEN: MRS ZAREEN SULTANA AGED ABOUT 56 YEARS, WIFE OF MR. AMEER SANANULLA KHAN RESIDING AT NO.12/1, 4th CROSS, MD BLOCK, CHAMARAJAPET, SIRSI ROAD, BANGALORE 560 018 …PETITIONER (BY SRI. SANDEEP HUILGOL.,ADVOCATE) AND: 1. THE ASSESSEMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, 2nd FLOOR, JAWAHARLAL NEHRU STADIUM, NEW DELHI 110 003 2. INCOME TAX OFFICER, WARD 5(2)(1), BANGALORE , BMTC BUILDING, 80 FEET ROAD, 6th BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA BANGALORE 560 095 3. INCOME TAX OFFICER WARD 3(1)(3), BANGALORE , BMTC BUILDING, 80 FEET ROAD, 6th BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA BANGALORE 560 095 Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:38145 WP No. 4179 of 2024 4. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KARNATAKA AND GOA REGION GROUND FLOOR, CR BUILDING, NO.1 QUEEN ROAD, BENGALURU 560 001 …RESPONDENTS (BY SRI. M.DILIP., ADVOCATE) THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE IMPUGNED NOTICE DATED 7.2.23 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2022-23/1049484904(1) ISSUED BY THE R2 UNDER SECTION 148A(B) OF THE INCOME TAX ACT, 1961, FOR THE ASSESSMENT YEAR 2016-17 (ANNEXURE-A)., AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN B GROUP, 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: "i. Quashing the impugned notice dated 07.02.2023 bearing DIN and Notice No. ITBA/AST/F/148A(SCN)/2022-23/1049484904(1) issued by the 2nd Respondent under Section 148A(b) of the Income-tax Act, 1961, for the assessment year 2016-17 (Annexure 'A') ii. Quashing the impugned notice dated 17.02.2023 bearing DIN and Notice No. ITBA/AST/F/148A(SCN)/2022-23/1049848220(1) issued by the 3rd Respondent under Section 148A(b) - 3 - HC-KAR NC: 2025:KHC:38145 WP No. 4179 of 2024 of the Income-tax Act, 1961, for the assessment year 2016-17 (Annexure 'B') iii. Quashing the impugned order dated 17.03.2023 bearing DIN and Notice No. ITBA/AST/F/148A/2022- 23/1050903151(1) passed by the 3rd Respondent under Section 148A(d) of the Income-tax Act, 1961, for the assessment year 2016-17 (Annexure 'C-1') iv. Quashing the impugned notice dated 17.03.2023 bearing DIN Notice No. ITBA/AST/S/148_1/2022- 23/1050903711(1) issued by the 3rd Respondent under Section 148 of the Income-Act, 1961, for the assessment year 2016-17 (Annexure 'C-2') v. Quashing the impugned assessment order dated 01.12.2023 bearing DIN No. ITBA/AST/S/147/2023- 24/1058411137(1) passed by the 1st Respondent under Section 147 read with Section 144 read with Section 144B of the Income-tax Act, 1961 for the assessment year 2016-17 (Annexure 'D-1') vi. Quashing the impugned computation sheet dated 01.12.2023 bearing DIN and Document No. ITBA/AST/S/114/2023 24/1058411154(1) issued by the 1st Respondent for the assessment year 2016-17 (Annexure 'D-2'); vii. Quashing the impugned demand notice dated 01.12.2023 bearing DIN and Notice No. ITBA/AST/S/156/2023-24/1058411155(1) issued by the 1st Respondent under Section 156 of the Income-tax Act, 1961 for the assessment year 2016- 17 (Annexure 'D-3'); viii. Quashing the impugned penalty notice dated 01.12.2023 bearing DIN No. ITBA/PNL/S/271F/2023- 24/1058411170(1) issued by the 1st Respondent under Section 274 read with Section 271F of the Income-tax Act, 1961 for the assessment year 2016- 17 (Annexure 'E-1') - 4 - HC-KAR NC: 2025:KHC:38145 WP No. 4179 of 2024 ix. Quashing the impugned penalty notice dated 01.12.2023 bearing DIN No. ITBA/PNL/F/271(1)(b)/2023-24/1058411168(1) issued by the 1st Respondent under Section 274 read with Section 271(1)(b) of the Income-tax Act, 1961 for the assessment year 2016-17 (Annexure 'E- 2) x. Quashing the impugned penalty notice dated 01.12.2023bearing No. ITBA/PNL/S/271(1)(c)/2023- 24/1058411169(1) issued by the 1 Respondent under Section 274 read with Section 271(1)(c) of the Income-tax Act, 1961 for the assessment year 2016- 17 (Annexure 'E-3); and xi. Pass such other or further order as this Hon'ble Court may deem fit in the facts and circumstances of the case, and in the interests of justice and equity." 2. Heard Sri Sandeep Huilgol, 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 - 5 - HC-KAR NC: 2025:KHC:38145 WP No. 4179 of 2024 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. (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 in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE BSV List No.: 1 Sl No.: 0