- 1 - HC-KAR NC: 2025:KHC:42399 WP No. 30296 of 2025 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. 30296 OF 2025 (T-IT) BETWEEN: PRAKASH VARADARAJ AGED ABOUT 50 YEARS, SON OF SRI VARADARAJ, INDIAN ADDRESS NO. 3-29-4, NEKKILA THOTA HOUSE, DEREBAIL, ASHOKNAGAR, MANGALORE, DAKSHINA KANNADA DISTRICT – 575 006. PREVIOUSLY AT, PALLIKERE COMPLEX, MAIDAN 4TH CROSS, BUNDER 575 001. ALSO AT: FLAT NO. 901, MOHAMMAD AHMAD MOHAMMAD AL-ZAROONI BUILDING, AL-NAHDA SECOND, DUBAI REPRESENTED BY HIS GPA HOLDER, SRI DHEERAJ P, AGED ABOUT 20 YEARS, SON OF SRI PARMESH, RESIDING AT NO. 53, 1ST FLOOR, 3RD CROSS, K NARAYANAPURA MAIN ROAD, SHIRADI SAI NAGAR, BENGALURU – 560 077. …PETITIONER (BY SRI. SACHIN S NAYAK.,ADVOCATE) AND: 1. INCOME TAX OFFICER WARD 1(1), MANGALORE C.R. BUILDING, N G ROAD, ATTAWARA, MANGALORE 575001 2. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA GOA REGION, BENGALURU Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:42399 WP No. 30296 of 2025 THE SPECIFIED AUTHORITY UNDER SECTION 151 OF THE INCOME TAX ACT, 1961 CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU – 560 001. 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). 4. ASSESSMENT UNIT A UNIT CREATED 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). 5. INCOME TAX OFFICER, WARD INTERNATIONAL TAXATION 1(2), BENGALURU THE JURISDICTIONAL ASSESSING OFFICER, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BENGALURU – 560 095. …RESPONDENTS (BY SRI. TIRUMALESH, ADVOCATE FOR R-1 TO R-4 SRI. E.I.SANMATHI, ADVOCATE FOR R-5) THIS W.P IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR ANY OTHER SUITABLE WRIT FOR QUASHING OF THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED NOTICE U/S 148A(B) OF THE INCOME TAX ACT, 1961 DATED 03/02/2023 ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2016-17 WHICH BEARS THE DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2022- 23/1049371119(1) AND ENCLOSED AS ANNEXURE A. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:42399 WP No. 30296 of 2025 CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, the petitioner seeks the following reliefs: “ a. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice u/s 148A(b) of the Income Tax Act, 1961 dated 03/02/2023 issued by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN & Notice No. ITBA/AST/F/148A(SCN)/2022- 23/1049371119(1) and enclosed as Annexure A b. Issue a writ of certiorari or any other suitable writ for quashing of the electronically communicated approval under section 151 of the Income Tax Act, 1961, dated 09/03/2023 issued by the Respondent No. 2 for the Assessment Year 2016-17 which bears the DIN: ITBA/AST/5/118/2022- 23/1050552908(1) and enclosed as Annexure B. c. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated order u/s 148A(d) of the Income Tax Act, 1961, dated 15/03/2023 issued by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN & Notice No. ITBA/AST/F/148A/2022-23/1050773937(1) and enclosed as Annexure C. d. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically - 4 - HC-KAR NC: 2025:KHC:42399 WP No. 30296 of 2025 communicated notice u/s 148 of the Income Tax Act, 1961, dated 20/03/2023 issued by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN &. Notice No. ITBA/AST/S/148_1/2022-23/1050988804(1) and enclosed as Annexure D. e. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated assessment order under section 147 r.w.s 144 of the Income Tax Act, 1961 dated 06/03/2024 passed by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/AST/S/147/2023-24/1062077053(1) and enclosed as Annexure N1. f. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice of demand under section 156 of the Income Tax Act, 1961 dated 06/03/2024 issued by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN & Notice No. ITBA/AST/S/156/2023- 24/1062077255(1) and enclosed as Annexure N2. g. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated computation sheet dated 06/03/2024 issued by the Respondent No. 1 for the Assessment Year. 2016-17 which bears the DIN & Document No. ITBS/AST/S/114/2023- 24/1062077164(1) and enclosed as Annexure N3. h. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically - 5 - HC-KAR NC: 2025:KHC:42399 WP No. 30296 of 2025 communicated order under section 271F of the Income-tax Act, 1961 dated 24/07/2024 issued by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN Notice No. ITBA/PNL/F/271F/2024-25/1066982517(1) and enclosed as Annexure P1. & i. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice of demand under section 156 of the Income Tax Act, 1961, dated 24/07/2024 issued by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN & Notice No. ITBA/AST/S/156/2024- 25/1066976949(1) and enclosed as Annexure P2. j. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated order under section 271(1)(c) of the. Income- tax Act, 1901 dated 30/07/2024 issued by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN & Notice No. ITBA/PNL/F/273(1)(6)/2024-25/1067163666(1) and enclosed as Annexure Q1 k. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice of demand under section 156 of the Income Tax Act, 1961, dated 30/07/2024 issued by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN & Notice No. ITBA/AST/5/156/2024- 25/1067163445(1) and enclosed as Annexure Q2. l. Grant such other reliefs as this Hon'ble Court deems f in this matter including but not limited to COST OF THE PETITION. - 6 - HC-KAR NC: 2025:KHC:42399 WP No. 30296 of 2025 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. 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: - 7 - HC-KAR NC: 2025:KHC:42399 WP No. 30296 of 2025 "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. (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: - 8 - HC-KAR NC: 2025:KHC:42399 WP No. 30296 of 2025 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- A, B, C, D, N1, N2, N3, P1, P2, Q1 and Q2 dated 03.02.2023, 09.03.2023, 15.03.2023, 20.03.2023, 06.03.2024, 06.03.2024, 06.03.2024, 24.07.2024, 24.07.2024, 30.07.2024 and 30.07.2024 respectively are hereby quashed. (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.: 98