- 1 - HC-KAR NC: 2025:KHC:30738 RP No. 520 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 7TH DAY OF AUGUST, 2025 BEFORE THE HON'BLE MR. JUSTICE S SUNIL DUTT YADAV REVIEW PETITION NO.520 OF 2024 BETWEEN: 1. INCOME TAX OFFICER, ITO WARD 1 AND TPS, AYAKAR BHAVAN, MALPE ROAD, AADI UDUPI, AMBALPADI (PO), UDUPI-576103. 2. NATIONAL FACELESS ASSESSMENT CENTRE, ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110003. 3. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, THE OFFICE OF THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, Digitally signed by VINAYAKA B V Location: High Court of Karnataka, Dharwad Bench - 2 - HC-KAR NC: 2025:KHC:30738 RP No. 520 of 2024 C. R. BUILDING, QUEENS ROAD, BANGALORE-560001. …PETITIONERS (BY SRI. THIRUMALESH M., ADVOCATE) AND: SHIVALI CREDIT CO-OPERATIVE SOCIETY LIMITED, REGISTERED UNDER THE KARNATAKA CO-OPERATIVE SOCIETIES ACT, 1959, REPRESENTED BY PRAKASH KARANTH, VICE PRESIDENT, 1ST FLOOR, SHIROOR MUTT BUILDING, RAJANGANA ROAD, UDUPI-576101, PAN: AADAS6306F, ALSO AT PRAKASH KARATH, AGED ABOUT 61 YEARS, S/O. LAKSHMINARAYAN KARATH, NO.7-498, MEENA LAXMI, NITTUR POST, NITTUR, UDUPI-576103. …RESPONDENT (BY SRI. RAVISHANKAR S.V., ADVOCATE) THIS REVIEW PETITION IS FILED UNDER XLVII RULE 1 READ WITH SECTION 114 OF THE CPC, PRAYING TO REVIEW THE ORDER DATED 19.06.2024 PASSED BY THIS HON’BLE COURT IN WP NO.13598/2024 AND ETC. THIS REVIEW PETITION, COMING ON FOR HEARING ON IA, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S SUNIL DUTT YADAV - 3 - HC-KAR NC: 2025:KHC:30738 RP No. 520 of 2024 ORAL ORDER (PER: THE HON'BLE MR. JUSTICE S.SUNIL DUTT YADAV) The present Review Petition has been filed seeking for review of the order dated 19.06.2024 passed by this court in W.P.No.13598/2024. 2. This court by order dated 19.06.2024 passed in W.P.No.13598/2024 had set aside the notice under Section 148A (b) of the Income Tax Act, 1961 (“the Act”, for short), apart from setting aside other proceedings at Annexure-A1, A2, A3, A4 and A5. This court had reserved liberty to take appropriate action to the Revenue in terms of Section 148A (b) of the Act. 3. Sri.Thirumalesh, learned counsel for Revenue draws attention to the order under Section 148A (d) and in particular, to the observations made at para 8, wherein there is a reference to the reply of the assessee. It is submitted that if that were to be so, mere sending of - 4 - HC-KAR NC: 2025:KHC:30738 RP No. 520 of 2024 notice to the wrong Email ID which has not caused prejudice and ought to be ignored. 4. Learned counsel for petitioner submits that insofar as 148A (b) notice, there are other contentions as well including that the sanction for initiating the proceedings under Section 148A (b) was defective and that they must be given opportunity to raise such contention. 5. Taking note of the submissions of both sides including that of the Revenue, it would be appropriate to review the order passed. 6. In light of apparent error as pointed out by the learned counsel for revenue which according to him was not referring to the reply notice which aspect was not brought to the notice of the court, it would be appropriate to review the order dated 19.06.2024 passed in W.P.No.13598/2024. 7. Accordingly, the order dated 19.06.2024 passed in W.P.No.13598/2024 is reviewed by recalling the same and - 5 - HC-KAR NC: 2025:KHC:30738 RP No. 520 of 2024 consequently restoring the writ petition to its original file. The Registry is directed to list W.P.No.13598/2024 before the Roster Bench next week. 9. Accordingly, the Review Petition is disposed off. Sd/- (S SUNIL DUTT YADAV) JUDGE NP /CT-AN List No.: 19 Sl No.: 1