- 1 - HC-KAR NC: 2025:KHC:39273 WP No. 12788 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 12788 OF 2025 (T-IT) BETWEEN: 1. ANANDA RAJU KRISHNAPPA SON OF S. KRISHNAPPA, AGED ABOUT 42 YEARS, NO.9, 2ND MAIN, 1ST A CROSS, BEHIND AMAR JOTHI PARK, RT NAGAR POST, KUPPUSWAMY GARDEN, BENGALURU - 560 032 …PETITIONER (BY SRI. RAVI SHANKAR S.V., ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD - 5(3)(2), NO.59, HMT BHAVAN, 4TH FLOOR, BELLARY ROAD, GANGANAGAR, BENGALURU - 560 032 2. THE PRINICIPAL COMMISSIONER OF INCOME TAX - 3, BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39273 WP No. 12788 of 2025 KORAMANGALA, BENGALURU - 560 095 3. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 …RESPONDENTS (BY SRI. M. THIRUMALESH, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE UNSIGNED SANCTION DATED 27.03.2024 ACCORDED UNDER SECTION 151 OF THE ACT FOR THE 2020-21 BY THE RESPONDENT NO.2 BEARING DIN ITBA/AST/S/118/2023- 24/1063467992(1) HEREIN MARKED AS ANNEXURE-A AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39273 WP No. 12788 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 unsigned sanction dated 27.03.2024 accorded under section 151 of the Act for the 2020-21 by the Respondent No.2 bearing DIN ITBA/AST/S/118/2023-24/1063467992(1) marked as Annexure - A. b) 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 for the AY 2020-21 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/148_1/2023- 24/1063526988(1) herein marked as Annexure - A1. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the assessment order dated 07.02.2025 passed under section 147 r.w.s. 144 of the Act for the AY 2020-21 by the Respondent No. 3 bearing DINS ITBA/AST/S/147/2024- 25/1073180729(1), ITBA/AST/S/330/2024- 25/1073189186(1) and ITBA/AST/S/156/2024- 25/1073189328(1) for the assessment order, computation sheet and the demand notice respectively herein marked as Annexure - A2. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty show cause notice dated 07.02.2025 issued under section 274 r.w.s. 270A of the Act for the AY 2020-21 by the Respondent No. 3 bearing DIN No. ITBA/PNL/S/270A/2024-25/1073188791(1) herein marked as Annexure - A3. - 4 - HC-KAR NC: 2025:KHC:39273 WP No. 12788 of 2025 e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty show cause notice dated 07.02.2025 issued under section 274 r.w.s. 271A of the Act for the AY 2020-21 by the Respondent No.3 bearing DIN No. ITBA/PNL/S/271A/2024-25/1073188740(1) herein as Annexure- A4. f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty show cause notice dated 07.02.2025 issued under section 274 r.w.s. 271B of the Act for the AY 2020-21 by the Respondent No. 3 bearing DIN No. ITBA/PNL/S/271B/2024-25/1073188824(1) herein marked as Annexure - A5. g) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty show cause notice dated 07.02.2025 issued under section 274 r.w.s. 272A(1)(d) of the Act for the AY 2020-21 by the Respondent No. 3 bearing DIN No. ITBA/PNL/S/272A(1)(d)_FL/2024-25/1073022516(1) herein marked as Annexure - A6. h) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Sri Ravishankar S.V., learned counsel for the petitioner and Sri M. Thirumalesh, 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 - 5 - HC-KAR NC: 2025:KHC:39273 WP No. 12788 of 2025 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 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 - 6 - HC-KAR NC: 2025:KHC:39273 WP No. 12788 of 2025 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE SJK CT:SG List No.: 2 Sl No.: 85