- 1 - HC-KAR NC: 2025:KHC:36581 WP No. 9385 of 2024 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. 9385 OF 2024 (T-IT) BETWEEN: M/S MYSORE DISTRICT JUDICIAL EMPLOYEES CREDIT CO OPERATIVE SOCIETY LIMITED REPRESENTED BY ITS PRESIDENT SRI.M.V. SHESHADRI AGED ABOUT 56 YEARS SON OF SRI.M.VISWESHWARIAH MYSORE AND CHAMARAJANAGAR DISTRICT JUDICIAL EMPLOYEES CREDIT CO-OPERATIVE SOCIETY LIMITED, OFFICE AT MYSORE LAW COURT PREMISES CHMARAJPURAM, MYSORE - 570 005. …PETITIONER (BY SRI. ANNAMALAI S., ADVOCATE) AND: 1. ASSESSMENT UNIT INCOME TAX DEPARTMENT, REPRESENTED BY ADDITIONAL/ JOINT/ DEPUTY/ ASSISTANT COMMISSIONER OF INCOME-TAX/ INCOME - TAX OFFICER, INCOME - TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 4-1, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:36581 WP No. 9385 of 2024 2. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1) AND TPS, MYSORE, ROOM NO. 113, IST FLOOR, AYAKAR BHAVAN, REAC, MYSORE – 570 008. 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU -3, BMTC BUILDING, 80 FT ROAD, 6TH BLOCK, KORAMANGALA, BENGALURU – 560 095. …RESPONDENTS (BY SRI. E.I.SANMATHI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLE 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO QUASH THE ASSESSMENT ORDER PASSED UNDER SECTION 147 RWS 144B OF THE ACT DTD. 28.02.2024 BEARING DIN NO. ITBA/AST/S/147/2023-24/1061702522(1) ISSUED BY THE R-1 FOR THE ASSESSMENT YEAR 2018-19 HEREIN MARKED AS ANNX-A1. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayer: - 3 - HC-KAR NC: 2025:KHC:36581 WP No. 9385 of 2024 “i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the assessment order passed under section 147 rws 144B of the Act dated 28/02/2024 bearing DIN No. ITBA/AST/S/147/2023-24/1061702522(1) issued by the Respondent No. 1 for the assessment year 2018-19 herein marked as Annexure - A1. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 28/02/2024 bearing DIN & Document No. ITBA/AST/S/185/2023-24/1061702547(1) Issued by the Respondent No. 1 for the assessment year 2018-19 herein marked as Annexure A2. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the demand notice dated 28/02/2024 issued under section 156 of the Act bearing DIN & Notice No. ITBA/AST/S/156/2023-24/1061702542(1) issued by the Respondent no. 1 for the assessment year 2018-19 herein marked as Annexure A3. iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 28/02/2024 issued under section 274 rws 270A of the Act bearing DIN No. ITBA/PNL/S/270A/2023-24/1061702568(1) issued by the Respondent No. 1 for the assessment year 2018-19 herein marked as Annexure A4. v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 28/02/2024 issued under section 274 rws 271AAC(1) of the Act - bearing DIN & Notice No. issued ITBA/PNL/F/271AAC(1)/2023- 24/1061702570(1) by the Respondent No. 1 for the assessment year 2018-19 herein marked as Annexure - A5. vi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 28/02/2024 issued under section 274 rws 271A of the Act bearing DIN No. ITBA/PNL/S/271A/2023-24/1061702569(1) Issued - 4 - HC-KAR NC: 2025:KHC:36581 WP No. 9385 of 2024 by the Respondent No. 1 for the assessment year 2018-19 herein marked as Annexure A6. vii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 28/02/2024 issued under section 274 rws 271B of the Act of bearing DIN No. ITBA/PNL/S/271B/2023-24/1061702571(1) issued by the Respondent No. 1 for the assessment year 2018-19 herein marked as Annexure A7. viii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 28/02/2024 issued under Section 274 rws 272A(1)(d) of the Act bearing DIN No. ITBA/PNL/S/272A(1)(d)-FL/2023-24/1061688729 (1) issued by the Respondent No. 1 for the assessment year 2018-19 herein marked as Annexure A8. ix) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 22/03/2022 issued under section 148A(b) of the Act bearing DIN & Notice No. ITBA/AST/F/148A(SCN)/2021-22/1041260118(1) issued by the Respondent No. 2 for the assessment year 2018-19 herein marked as Annexure - B1. x) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed under Section 148A(d) of the Act dated 04/04/2022 bearing DIN & Notice No. ITBA/AST/F/148A/2022- 23/1042490800(1) issued by the Respondent No. 2 for the assessment year 2018-19 herein marked as Annexure - B2. xi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 04/04/2022 issued under section 148 of the Act bearing DIN & Notice No. ITBA/AST/S/148_1/2022- 23/1042491063(1) issued by the Respondent No. 2 for the assessment year 2018-19 herein marked as Annexure - B3. - 5 - HC-KAR NC: 2025:KHC:36581 WP No. 9385 of 2024 xii) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri Annamalai S., 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 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 this petition would stand quashed. - 6 - HC-KAR NC: 2025:KHC:36581 WP No. 9385 of 2024 (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. (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.: 363