- 1 - HC-KAR NC: 2025:KHC:38626 WP No. 12141 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28TH DAY OF AUGUST, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO.12141 OF 2025 (T-IT) BETWEEN: RANGA SWAMY SON OF DORESWAMY, AGED ABOUT 56 YEARS, 2ND MAIN, 3RD CROSS, DEVARANA PATTANA, BATAWADI PRASHANTH NAGARA, TUMKUR – 572 103, KARNATAKA …PETITIONER (BY SRI. MADHUSUDHAN U A.,ADVOCATE) AND: 1. THE ASSESSMENT UNIT INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWARLAL NEHRU STADIUM, DELHI - 110 003 2. THE INCOME TAX OFFICER WARD 1 AND TPS Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:38626 WP No. 12141 of 2025 AAYAKAR BHAVAN RAMAKRISHNAGARA KUNIGAL ROAD RAMAKRISHNA NAGAR TUMKUR KARNATAKA – 572 103 3. THE PRINICIPAL COMMISSIONER OF INCOME TAX, BEGNALURU 2 BMTC BULDING, 80 FEET ROAD 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU KARNATAKA – 560 095 …RESPONDENTS (BY SRI. E. I. SANMATHI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE ASSESSMENT ORDER DATED 31.12.2024 PASSED UNDER SECTION 147 R.W.S 144 R.W.S 144B OF THE ACT FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO.1 BEARING DIN NO.ITBA/AST/S/147/2024- 25/1071746053(1) HEREIN MARKED AS ANNEXURE-A1 AND ETC THIS PETITION COMING ON FOR PRELIMINARY HEARING THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:38626 WP No. 12141 of 2025 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 direction in the nature of a writ of certiorari quashing the assessment order dated 31.12.2024 passed under section 147 r.w.s 144 r.w.s 144B of the Act for the Assessment Year 2020-21 by the Respondent No.1 bearing DIN No. ITBA/AST/S/147/2024-25/1071746053(1) herein marked as Annexure - A1. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 31.12.2024 issued by the Respondent No.1 for the Assessment Year 2020-21 bearing DIN & Document No. ITBA/AST/S/330/2024- 25/1071746328(1) herein marked as Annexure - A2. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand issued under section 156 of the Act dated 31.12.2024 by the Respondent No.1 for the Assessment Year 2020-21 bearing DIN & Notice No. ITBA/AST/S/156/2024-25/1071746429(1) herein marked as Annexure - АЗ. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 31.12.2024 passed under section 272A(1)(d) of the Act by the Respondent No.1 for the Assessment Year 2020-21 DIN bearing No. ITBA/PNL/S/272A(1)(d)_FL/2024- 25/1071733914(1) herein marked as Annexure - A4. - 4 - HC-KAR NC: 2025:KHC:38626 WP No. 12141 of 2025 e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 31.12.2024 passed under section 271A of the Act by the Respondent No.1 for the Assessment Year 2020-21 bearing DIN No. ITBA/PNL/S/271A/2024-25/1071746254(1) herein marked as Annexure - A5. f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 31.12.2024 passed under section 271AAC(1) of the Act by the Respondent No.1 for the Assessment Year 2020-21 bearing DIN No. ITBA/PNL/S/271AAC(1)/2024-25/1071746255(1) herein marked as Annexure - A6. g) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 31.12.2024 passed under section 271B of the Act by the Respondent No.1 for the Assessment Year 2020-21 bearing DIN No. ITBA/PNL/S/271B/2024-25/1071746256(1) herein marked as Annexure - A7. h) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 148 of the Act dated 28.03.2024 of the Act for the Assessment Year 2020-21 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/148_1/2023-24/1063527075(1) herein marked as Annexure - B1. i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the approval dated 27.03.2024 passed under section 151 of the Act for the Assessment Year 2020-21 by the Respondent No.1 bearing DIN & Order No. ITBA/AST/S/118/2023-24/1063482564(1) herein marked as Annexure - B2. j) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” - 5 - HC-KAR NC: 2025:KHC:38626 WP No. 12141 of 2025 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 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned show cause notice 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:38626 WP No. 12141 of 2025 (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 NVJ List No.: 1 Sl No.: 423