- 1 - HC-KAR NC: 2025:KHC:39284 WP No. 13232 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. 13232 OF 2025 (T-IT) BETWEEN: 1. SMT.KRISHNA RAO NAGARAJA INDIRA D/O NAGARAJA K, AGED ABOUT 57 YEARS, SRINIVASA NILAYA, K.R. PURAM ROAD, NEAR VANDANA THEATRE, SHIVAMOGGA - 577 202 …PETITIONER (BY SRI. RAVI SHANKAR S.V., ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD-1 AND TPS, NO.75, 100 FEET ROAD, GOPAL GOWDA EXTENSION, SHIVAMOGA - 577 201 2. CHIEF COMMISSIONER OF INCOME TAX - 1 C.R. BUILDING, NO. 1, QUEENS ROAD, BENGALURU - 560 001 3. THE ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, REP. BY ADDL/JOINT/DEPUTY/ Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39284 WP No. 13232 of 2025 ASSISTANT COMMISSIONER OF INCOME TAX/INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, NEW DELHI - 110 003 …RESPONDENTS (BY SRI. M. DILLIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A) WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE ISSUED UNDER SECTION 148A(B) OF THE ACT DATED 29.01.2024 OF THE ACT AY 2017- 18 BY THE RESPONDENT NO. BEARING 1 ITBA/AST/F/148A(SCN)/2023-24/1060233302(1), MARKED AS ANNEXURE - A. DIN HEREIN MARKED AS ANNX-A. B) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE ISSUED UNDER SECTION 148A(B) OF THE ACT DATED 27.02.2024 OF THE ACT FOR THE AY 2017-18 BY THE RESPONDENT NO. 1 BEARING DIN ITBA/AST/F/148A(SCN)/2023-24/1061539064(1), HEREIN MARKED AS ANNEXURE - A1 AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39284 WP No. 13232 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 notice issued under section 148A(b) of the Act dated 29.01.2024 of the Act AY 2017-18 by the Respondent No. 1 bearing DIN ITBA/AST/F/148A(SCN)/2023- 24/1060233302(1), herein 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 148A(b) of the Act dated 27.02.2024 of the Act for the AY 2017-18 by the Respondent No. 1 bearing DIN ITBA/AST/F/148A(SCN)/2023- 24/1061539064(1), herein marked as Annexure - A1. c) Issue a Writ of Certiorari or direction in the nature of a Writ of Certiorari quashing the order dated 11.03.2024 passed under section 148A(d) of the Act for the AY 2017-18 by the Respondent No. 1 bearing DIN ITBA/AST/F/148A/2023- 24/1062385524(1), herein marked as Annexure - A2. d) Issue a Writ of Certiorari or direction in the nature of a Writ of Certiorari quashing the notice dated 11.03.2024 issued under section 148 of the Act for the AY 2017-18 by the Respondent No. 1 bearing DIN ITBA/AST/S/148_1/2023-24/1062392640(1), herein marked as Annexure - A3. e) Issue a Writ of Certiorari or direction in the nature of a Writ of Certiorari quashing the assessment order dated 26.03.2025 passed under section 147 r.w.s. 144 of the Act for the AY 2017-18 by the - 4 - HC-KAR NC: 2025:KHC:39284 WP No. 13232 of 2025 Respondent No. 1 bearing DINs ITBA/AST/S/147/2024-25/1075071668(1), ITBA/AST/S/156/2024-25/1075071799(1) & ITBA/AST/S/213/2024-25/1075071751(1) for the assessment order, demand notice and computation sheet respectively, herein collectively marked 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 26.03.2025 issued under section 270A of the Act for the AY 2017-18 by the Respondent No. 1 bearing DIN ITBA/PNL/S/270A/2024-25/1075071774(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 27.03.2025 issued under section 271AAC(1) of the Act for the AY 2017-18 by the Respondent No.1 bearing DIN ITBA/PNL/S/271AAC(1)/2024-25/1075107147(1), herein marked as Annexure - A6. h) Issue a Writ of Certiorari or direction in the nature of a Writ of Certiorari quashing the penalty show cause notice dated 26.03.2025 issued under section 271F of the Act for the AY 2017-18 by the Respondent No. 1 bearing DIN ITBA/PNL/S/271F/2024-25/1075075287(1), herein marked as Annexure - A7. i) 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. Dilip, learned counsel for the respondents. - 5 - HC-KAR NC: 2025:KHC:39284 WP No. 13232 of 2025 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 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. - 6 - HC-KAR NC: 2025:KHC:39284 WP No. 13232 of 2025 (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 SJK CT-SG List No.: 2 Sl No.: 90