- 1 - HC-KAR NC: 2025:KHC:40170 WP No. 30612 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 10TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 30612 OF 2025 (T-IT) BETWEEN: SRI APPAJI HEALTH AND WELFARE TRUST, REGISTERED UNDER TRUST DEED DATED 07/01/2002, PAVAMANAPURA, SRSM LAYOUT, LINGADAIRANA HALLI TALAGATTAPURR POST, BANGALORE - 560 062 PAN: AAFTS8638H REPRESENTED BY ITS PRESIDENT DR. K R SAMPATHACHAR, AGED 91 YEARS, S/O LATE K. RAMASWAMY IYENGAR, NO.440, 44TH CROSS, 8TH BLOCK, JAYANAGAR, PADMANABHNAGAR S.O, BANGALORE - 560 070. …PETITIONER (BY SRI. RAVI SHANKAR S. V., ADVOCATE) AND: 1. INCOME TAX OFFICER EXEMPTIONS WARD-3, UNITY BUILDING ANNEXE, MISSION ROAD, BANGALORE - 560 027 2. NATIONAL FACELESS ASSESSMENT CENTRE, ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY O FINANCE, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:40170 WP No. 30612 of 2025 3. COMMISSIONER OF INCOME TAX (EXEMPTIONS), OFFICE OF THE COMMISSIONER OF INCOME TAX (EXEMPTIONS) UNITY BUILDING ANNEXE, MISSION ROAD, BANGALORE - 560 027 …RESPONDENTS (BY SRI. ARAVIND V. CHAVAN, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE UNDER SECTION 148A(B) OF THE ACT DATED 05.01.2024 BEARING DIN NO. ISSUED ITBA/AST/F/148A(SCN)/2023-24/1059393606(1) BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2020-21 HEREIN MARKED AS ANNEXURE A 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: "i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148A(b) of the Act dated 05/01/2024 bearing DIN No.ITBA/AST/F/148A(SCN)/2023-24/1059393606(1) issued by the Respondent No.1 for the assessment year 2020-21 herein marked as Annexure - A. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order under Section 151 of the Act dated 14/02/2024 without DIN, passed by the Respondent No.3 for the assessment year 2020- 21 herein marked as Annexure - A1. - 3 - HC-KAR NC: 2025:KHC:40170 WP No. 30612 of 2025 iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the intimation letter dated 15/02/2024 for the order under section 151 of the Act vide ITBA/COM/S/91/2023-24/1060977992(1) issued by the Respondent No.3 for the assessment year 2020-21 herein marked as Annexure - A2. iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order under Section 148A(d) of the Act dated: 16/02/2024 bearing DIN No.ITBA/AST/F/148A/2023-24/1061038145(1) passed by the Respondent No.1 for the assessment year 2020-21 herein marked as Annexure-A3. v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148 of the Act dated: 16/02/2024 bearing DIN No.ITBA/AST/S/148_1/2023-24/1061038842(1) issued by the Respondent No.1 for the assessment year 2020-21 herein marked as Annexure-A4. vi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed U/s. 147 r.w.s.144, 144B dated: 07/03/2025 bearing ITBA/AST/S/147/2024-25/1074193988(1) passed by the Respondent No.2 for the assessment year 2020- 21 herein marked as Annexure-A5. vii) Issue a writ of Certiorari or direction in the nature of a writ of Certiorari quashing the penalty order was passed u/s 272A(1) (d) of the Act dated: 17/09/2025 bearing DIN No. ITBA/PNL/F/272A(1)(d)/2025- 26/1080852661(1) by the Respondent No.2 for the - 4 - HC-KAR NC: 2025:KHC:40170 WP No. 30612 of 2025 assessment year 2020-21 herein marked as Annexure-A6. viii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order was passed U/s 270Aof the Act dated:23/09/2025 bearing DIN No.ITBA/PNL/F/270A/2025-26/1081075531(1), by the Respondent No.2 for the assessment year 2020-21 herein marked as Annexure-A7. ix) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order was passed u/s 271AACC(1) of the Act dated:23/09/2025 bearing DIN No.ITBA/PNL/S/271AAC(1)/2025- 26/1081082161(1) by the Respondent No.2 for the assessment year 2020-21 herein marked as Annexure-A8. x) And pass such other orders as this Hon'ble Court deems fit and proper 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 - 5 - HC-KAR NC: 2025:KHC:40170 WP No. 30612 of 2025 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. 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 - 6 - HC-KAR NC: 2025:KHC:40170 WP No. 30612 of 2025 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. (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, A1, A2, A3, A4, A5, A6, A7 and A8 dated 05.01.2024, 14.02.2024, - 7 - HC-KAR NC: 2025:KHC:40170 WP No. 30612 of 2025 15.02.2024, 16.02.2024, 16.02.2024, 07.03.2025, 17.09.2025, 23.09.2025 and 23.09.2025 respectively are hereby quashed. (iii) Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, subsequent 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 Srl.