- 1 - HC-KAR NC: 2025:KHC:42400 WP No. 15848 of 2023 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 15848 OF 2023 (T-IT) BETWEEN: DIVYA HEMANTH REPRESENTED BY GPA HOLDER SRI G. L. VEMANATH, SON OF LATE SRI G. LAXMAN NAIDU, AGED ABOUT 70 YEARS, H.NO. 1792, 18TH MAIN, 2ND JPHASE, J P NAGAR, BENGALURU – 560 078. …PETITIONER (BY SRI. SHREEHARI KUTSA, ADVOCATE) AND: 1. INCOME TAX OFFICER, WARD 4 (3) (3) BENGALURU THE ASSESSING OFFICER UNDER THE INCOME TAX ACT, 1961 BMTC BUILDING, 80 FT ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORMANGALA, BENGALURU – 560 095. 2. PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU-2 THE APPROVING AUTHORITY UNDER THE SECTION 151 OF INCOME TAX ACT, 1961 BMTC BUILDING, 80 FT ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORMANGALA, BENGALURU – 560 095. Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:42400 WP No. 15848 of 2023 3. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC) A CENTRE DESCRIBED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961 ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI – 110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC) …RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE U/S 148A(b) OF THE INCOME TAX ACT, 1961 DATED 11.03.2022 ISSUED BY THE RESPONDENT NO.1 WHICH BEARS THE DIN - ITBA/AST/F/148A(SCN)/2021-22/1040592442(1) AND ENCLOSED AS ANNEXURE-D 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 of Certiorari or direction in the nature of writ of certiorari quashing the notice under section 148A(b) of the Income Tax Act, 1961 dated 11.03.2022 issued by the Respondent No.1 which bears the DIN – ITBA/AST/F/148A(SCN)/2021- 22/1040592442(1) and enclosed as Annexure D. b. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the order under section 148A(d) of the Income Tax Act, 1961 dated 31.03.2022 issued by the Respondent No.1 which - 3 - HC-KAR NC: 2025:KHC:42400 WP No. 15848 of 2023 bears the DIN – ITBA/AST/F/148A/2021- 22/1042297433(1) and enclosed as Annexure-F. c. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the notice under section 148 of the Income Tax Act, 1961 dated 31.03.2022 issued by the Respondent No.1 which bears the DIN – ITBA/AST/F/148_1/2021-22/1042347134(1) and enclosed as Annexure-G. d. Invoking the extra-ordinary jurisdiction of this Hon’ble Court seeking quashing of the notice under section 143(2) of the Income Tax Act, 1961 dated 28.06.2022 issued by the Respondent No.3 for the Assessment Year 2018-19 which bears the DIN: ITBA/AST/F/143(2)_5/2022-23/1045771513(1) and enclosed as Annexure-J. e. Invoking the extra-ordinary jurisdiction of this Hon’ble Court seeking quashing of the order of assessment under section 147 of the Income Tax Act, 1961 dated 27.03.2023 issued by the Respondent No.3 for the Assessment Year 2018-19 which bears the DIN viz., ITBA/AST/S/147/2022-23/1051406589(1) and enclosed as Annexure-P1. f. Invoking the extra-ordinary jurisdiction of this Hon’ble Court seeking quashing of the notice of demand under section 156 of the Income Tax Act, 1961 dated 27.03.2023 issued by the Respondent No.3 for the Assessment Year 2018-19 which bears the DIN viz., - 4 - HC-KAR NC: 2025:KHC:42400 WP No. 15848 of 2023 ITBA/AST/S/156/2022-23/1051407010(1) and enclosed as Annexure=P2. g. Invoking the extra-ordinary jurisdiction of this Hon’ble Court seeking quashing of the notice under section 270A of the Income Tax Act, 1961 dated 27.03.2023 issued by the Respondent No.3 for the Assessment Year 2018-19 which bears the DIN viz., ITBA/PNL.S.270A/2022-23/1051407301(1) and enclosed as Annexure-P3. h. And pass such other orders as this Hon’ble Court deems fit and proper in the interest of justice and equity.” 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 - 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. - 5 - HC-KAR NC: 2025:KHC:42400 WP No. 15848 of 2023 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. (iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. - 6 - HC-KAR NC: 2025:KHC:42400 WP No. 15848 of 2023 (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- D, F, G, J, P1, P2 and P3 dated 11.03.2022, 31.03.2022, 31.03.2022, 28.06.2022, 27.03.2023, 27.03.2023 and 27.03.2023 respectively are hereby quashed. - 7 - HC-KAR NC: 2025:KHC:42400 WP No. 15848 of 2023 (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 MDS List No.: 3 Sl No.: 24