- 1 - HC-KAR NC: 2025:KHC:37386 WP No. 13334 of 2023 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 13334 OF 2023 (T-IT) BETWEEN: CHITRAPURA KRISHNA PRASAD S/O C ANANTHANARAYANA AGED ABOUT 48 YEARS NO.323, 3RD CROSS, 2ND BLOCK, 3RD STAGE, BASAVESHWARA NAGAR BANGALORE - 560 079 PAN ACFPP7099B …PETITIONER (BY SRI. SUDHEENDRA B.R, ADVOCATE) AND: 1. ASSISTANT/DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 5(3)(2) BANGALORE, BMTC BUILDING 6TH BLOCK, KORAMANGALA BANGALORE - 560 095. 2. INCOME TAX OFFICER, WARD 6(2)(1) ROOM NO.310, 3RD FLOOR, BMTC BUILDING KORAMANGALA, BANGALORE - 560 095. 3. PRINCIPAL COMMISSIONER OF INCOME TA BENGALURU-1, BENGALURU 5TH FLOOR, 80 FEET ROAD, BMTC BUILDING, 6TH BLOCK Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37386 WP No. 13334 of 2023 NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU - 560 095 REPRESENTING THE NATIONAL FACELESS ASSESSMENT CENTRE 4. CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE, MINISTRY OF FINANCE NORTH BLOCK, NEW DELHI - 110 002 REPRESENTED HEREIN BY ITS CHAIRPERSON 5. NATIONAL FACELESS ASSESSMENT CENTRE REP BY 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 - 110 003. …RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO-QUASH THE ORDER U/S 148A(d) DTD 19/07/2022 PASSED BY THE ITO, WARD 6(2)(1), BANGALORE I.E., R-2 FOR THE AY 2016-17 (ANNEXURE-E1) AND ETC., THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:37386 WP No. 13334 of 2023 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “(A) Quashing the Order under section 148A(d) dated 19.7.2022 passed by the ITO, Ward 6(2)(1), Bangalore i.e., respondent no 2 for the AY 2016- 17 (Annexure E1) (B) Quashing the Notice under section 148 dated 28.7.2022 issued by the ITO, Ward 6(2)(1), Bangalore i.e., respondent no 2 for the AY 2016- 17 (Annexure E2) (C) Quashing the Assessment order under section 147 rws 1448 passed by the Assessment Unit, National Faceless Assessment Centre i.e., respondent no 5 dated 23.5.2023 with DIN ITBA/AST/S/147/2023- 24/1053094054(1) for the AY 2016-17 (Annexure P1) (D) Quashing the Computation sheet passed by the Assessment Unit, National Faceless Assessment Centre i.e., respondent no 5 dated 23.5.2023 with DIN & Document No ITBA/AST/S/114/2023- 24/1053094151(1) for the AY 2016-17 (Annexure P2) (E) Quashing the Notice of demand under section 156 passed by the Assessment Unit National Faceless Assessment Centre i.e., respondent no 5 dated 23.5.2023 with DIN & Notice No ITBA/AST/S/156/2023-24/1053094171(1) for the AY 2016-17 (Annexure P3) (F) Quashing the Notice for Penalty under section 274 read with section 271(1)(c) issued by the Assessment unit National Faceless Assessment Centre i.e., respondent no 5 dated 18.5.2023 with DIN ITBA/PNL/S/271(1)(c)/2023- - 4 - HC-KAR NC: 2025:KHC:37386 WP No. 13334 of 2023 24/1053094240(1) for the AY 2016-17 (Annexure P4) (G) Quashing the Instruction bearing No.1/2022 dated 11.05.2022 issued by the Respondent No. 4 (Annexure-Q) to the extent challenged in this writ petition And (H) Passing such other or further orders as this Honourable High Court may think fit in the facts and circumstances of the case, in the interests of justice and equity." 2. Heard Shri Sudheendra B.R., learned counsel appearing for the petitioner and Shri E.I. Sanmathi, learned counsel appearing 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: - 5 - HC-KAR NC: 2025:KHC:37386 WP No. 13334 of 2023 ORDER (i) The impugned show cause notice 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. (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 JY List No.: 1 Sl No.: 0 CT: BHK