- 1 - HC-KAR NC: 2025:KHC:42404 WP No. 31674 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. 31674 OF 2025 (T-IT) BETWEEN: RAYASHETTYPURA CHIKKLIGEGOWDA RAVISH, NO. 274, 9TH MAIN, 4TH A BLOCK, RPC LAYOUT, VIJAYANAGAR, BENGALURU – 560 040. AGED ABOUT 36 YEARS …PETITIONER (BY SRI. ASHOK A. KULAKARNI, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD 3(2)(1), BMTC BUILDING, 80 FT ROAD, 6TH BLOCK KORAMANGALA, BENGALURU, KARNATAKA – 560 095 2. CENTRAL BOARD OF DIRECT TAXES CENTRAL SECRETARIAT, NORTH BLOCK, NEW DELHI – 110 001 REPRESENTED BY THE ADDITIONAL/ JOINT /DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER/ NATIONAL FACELESS ASSESSMENT CENTRE. …RESPONDENTS (BY SRI. M. TIRUMALESH, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH BY AN ORDER, WRIT, OR DIRECTION IN THE NATURE OF CERTIORARI THE ORDER PASSED UNDER SECTION 148A(D) OF THE INCOME-TAX ACT, 1961 DATED 13.03.2024 FOR THE ASSESSMENT YEAR 2020- Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:42404 WP No. 31674 of 2025 21, BEARING DIN AND NOTICE NO. ITBA/AST/F/148A/2023- 24/1062534704(1) AND PRODUCED HEREWITH AS ANNEXURE A, ISSUED BY THE 1ST RESPONDENT, AS UNLAWFUL, ILLEGAL, WITHOUT JURISDICTION, AND VOID AB INITIO, ALONG WITH ALL ATTENDANT AND CONSEQUENTIAL ACTIONS 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, petitioner seeks for the following reliefs:- “A. Quash by an order, writ or direction in the nature of Certiorari the order passed under Section 148A(d) of the Income-tax Act, 1961 dated 13.03.2024 for the Assessment Year 2020-21, bearing DIN & Notice No.ITBA/AST/F/148A/2023-24/1062534704(1) and produced herewith as Annexure “A”, issued by the 1st Respondent, as unlawful, illegal, without jurisdiction, and void ab initio, along with all attendant and consequential actions. B. Quash by an order, writ or direction in the nature of Certiorari the notice issued under Section 148 of the Income-tax Act. 1961 dated 13.03.2024 for the Assessment Year 2020-21, bearing DIN & Notice No.ITBA/AST/S/148_1/2023-24/1062534902(1) and produced herewith as Annexure “B”, issued by the 1st Respondent, as unlawful, illegal, without jurisdiction, and void ab initio, along with all attendant and consequential actions. - 3 - HC-KAR NC: 2025:KHC:42404 WP No. 31674 of 2025 C. Quash by an order, writ or direction in the nature of Certiorari the reassessment order passed by the 2nd Respondent under Section 147 read with Sections 144 and 144B of the Income-tax Act, 1961 dated 27.02.2025 for the Assessment Year 2020-21, bearing DIN & Notice No. ITBA/AST/S/147/2024- 25/1073794581(1) and produced herewith as Annexure “C”, as unlawful, illegal, without jurisdiction, and void ab initio, along with all attendant and consequential actions. D. Grant such other relief that this Hon’ble Court may think fit including the cost of this petition in the interest of justice and equity.” 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 - HC-KAR NC: 2025:KHC:42404 WP No. 31674 of 2025 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: "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. - 5 - HC-KAR NC: 2025:KHC:42404 WP No. 31674 of 2025 (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: 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 and C dated 13.03.2024, 13.03.2024 and 27.02.2025 respectively are hereby quashed. (iii) Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, subsequent - 6 - HC-KAR NC: 2025:KHC:42404 WP No. 31674 of 2025 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.: 19