- 1 - HC-KAR NC: 2025:KHC:53310 WP No. 37639 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 15TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 37639 OF 2025 (T-IT) BETWEEN: 1. LAKSHMI H., AGED 27 YEARS, D/O LATE HARISH KUMAR.C, 2. HANSIKA H., AGED 17 YEARS D/O LATE HARISH KUMAR.C, (REP BY HER ELDER SISTER - PETITIONER NO. 1) RESIDING AT LAKSHMI NILAYA HOUSE NO.3, 3RD CROSS, NAGAPPA BLOCK, SRIRAMPURAM S.O, BANGALORE NORTH, BANGALORE – 560 021 …PETITIONERS (BY SRI. D. R. RAVISHANKAR, SENIOR COUNSEL FOR SRI. NAVEEN G. S., ADVOCATE) AND: 1. ASSISTANT COMMISSIONER OF INCOME TAX INCOME TAX, CENTRAL CIRCLE 2(4), BENGALURU, C.R. BUILDING, NO.1, QUEEN’S ROAD, BENGALURU – 560 001 2. SRI. SURESH KUMAR CHANNAPPA, AGED 56 YEARS, S/O LATE SRI CHANNAPPA, RESIDING AT NO. 391/141, 19TH MAIN ROAD, NEAR NARAYANA COLLEGE, 1ST BLOCK, RAJAJINAGAR, BANGALORE – 560 010 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE FOR R1; NOTICE TO R2 IS DISPENSED WITH) Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:53310 WP No. 37639 of 2025 THIS W.P. IS FILED UNDER SECTION 226 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR ANY OTHER APPROPRIATE WRIT, ORDER, OR DIRECTION, QUASHING THE IMPUGNED NOTICE ISSUED IN SO FAR A PETITIONERS ARE CONCERNED UNDER SECTION 142(1) OF INCOME TAX ACT, BEARING NO. ITBA/AST/M/142(1)/2025- 26/1082018850(1) DATED 27.10.2025, PERTAINING TO AY 2013-14, PRODUCED AT ANNEXURE-B ISSUED BY RESPONDENT-1 AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioners seek for the following reliefs:- “(a) Issue a Writ of Certiorari or any other appropriate writ, order, or direction, quashing the impugned notice issued in so far a Petitioners are concerned under Section 142(1) of Income Tax Act, bearing No.ITBA/AST/M/142(1)/2025-26/1082018850(1) dated 27.10.2025, pertaining to AY 2013-14, produced at Annexure-B issued by Respondent-1. (b) Issue a Writ of Certiorari or any other appropriate writ, order or direction, quashing the impugned notice issued in so far a Petitioners are concerned under Section 142(1) of Income Tax Act, bearing No.ITBA/AST/M/142(1)/2025-26/1082018997(1) dated 27.10.2025, pertaining to AY 2016-17, produced at Annexure-B-1 issued by Respondent-1. - 3 - HC-KAR NC: 2025:KHC:53310 WP No. 37639 of 2025 (c) Pass such other orders as may be deemed appropriate under the circumstances of the case, in the ends of justice.” 2. Heard learned counsel for the petitioners and learned counsel for the respondent No.1 and perused the material on record. 3. Service of notice to respondent No.2 is dispensed with. 4. Petitioners are addressee Nos.5 and 6 in the impugned notices for the assessment years 2013-14, 2016-17 and 2017-18 all dated 27.10.2025, being the grandchildren of late Channappa, being the children of late Harish Kumar, who was the son of late Channappa. The wife of the aforesaid late Channappa approached this Court in WP No.35585/2025, which was allowed and disposed of on 01.12.2025 as hereunder: “In this petition, the petitioner seeks the following reliefs: "a) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 31.03.2023 issued under section 148 of the Income Tax Act, 1961 for the assessment year 2013-14 by the Respondent No.1 bearing DIN & Notice No. ITBA/COM/M/17/2022- 23/1051782106(1) herein marked as Annexure - A1. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice - 4 - HC-KAR NC: 2025:KHC:53310 WP No. 37639 of 2025 dated 31.08.2024 issued under section 148 of the Income Tax Act, 1961 for the assessment year 2016-17 by the Respondent No.2 bearing DIN & Notice No. ITBA/COM/M/17/2024- 25/1068212979(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 dated 31.08.2024 issued under section 148 of the Income Tax Act, 1961 for the assessment year 2017-18 by the Respondent No.2 bearing DIN & Notice No. ITBA/COM/M/17/2024- 25/1068215811(1) herein marked as Annexure - A3. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 11.09.2025 issued under section 142(1) for the assessment year 2013-14 by the Respondent No.2 DIN bearing & Notice No. ITBA/AST/M/142(1)/2025-26/1080613054(1) herein marked as Annexure - B1. e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 11.09.2025 issued under section 142(1) for the assessment year 2016-17 by the Respondent No.2 bearing DIN B Notice No. ITBA/AST/M/142(1)/2025-26/1080613158(1) herein marked as Annexure - B2. f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 11.09.2025 issued under section 142(1) for the assessment year 2017-18 by the Respondent No.2 bearing DIN & Notice No. ITBA/AST/M/142(1)/2025-26/1080612468(1) herein marked as Annexure B3. g) 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:53310 WP No. 37639 of 2025 5. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 6. 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. 7. 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. 8. 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 - 6 - HC-KAR NC: 2025:KHC:53310 WP No. 37639 of 2025 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." 9. 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). 10. 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 - 7 - HC-KAR NC: 2025:KHC:53310 WP No. 37639 of 2025 Annexures- A1, A2, A3, B1, B2 and B3 dated 31.03.2023, 31.08.2024, 31.08.2024, 11.09.2025, 11.09.2025 and 11.09.2025, respectively, are hereby quashed, in so far as petitioners is concerned. 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 11. In view of the aforesaid facts and circumstances, the present petition also deserves to be allowed and disposed of in terms of judgment of this Court in the case of Mrs. K. B. Bhojamma Vs. The Deputy Commissioner of Income Tax and Ors. - WP No.35585/2025 dated 01.12.2025. 12. In the result, I pass the following: ORDER i) The petition is allowed and disposed of in terms of the decision of this Court in the case of Mrs. K. B. Bhojamma Vs. The Deputy Commissioner of Income Tax and Ors. - WP No.35585/2025 dated 01.12.2025. - 8 - HC-KAR NC: 2025:KHC:53310 WP No. 37639 of 2025 ii) The impugned show cause notices and consequential orders, notices etc., at Annexures- B, B-1 and B-2 all dated 27.10.2025 are hereby quashed, insofar as petitioners are concerned. 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.: 2 Sl No.: 12