- 1 - HC-KAR NC: 2025:KHC:25176 WP No. 12797 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 9TH DAY OF JULY, 2025 BEFORE THE HON'BLE MR. JUSTICE SURAJ GOVINDARAJ WRIT PETITION NO. 12797 OF 2024 (T-IT) BETWEEN: SHRI BANGALORE CHELUVA NARAYAN AGED ABOUT 65 YERAS, SON OF RAJAN BANGALORE CHELUVA R/AT #201, ASHWINI RESIDENCY, NEW BEL ROAD, SREENAPPA LAYOUT, RMV 2ND STAGE, BANGALORE-560011. ALSO R/AT C211, 45/6, NILADRI MAHDI, NANDI DURGA ROAD, JAYAMAHAL, BANGALORE-560046. …PETITIONER (BY SRI. SANDEEP HUILGOL AND B.C. NARAYAN, ADV.) AND: 1. THE ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, 2ND FLOOR, JAWAHARLAL NEHRU STADIUM, NEW DELHI-110003. 2. INCOME TAX OFFICER, WARD 1(2)(1), BANGALORE, BMTC BUILDING, 80FT ROAD, 6TH BLOCK, KORAMANGALA, BENGALURU-560095. Digitally signed by SHWETHA RAGHAVENDRA Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:25176 WP No. 12797 of 2024 3. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA AND GOA REGION, GROUND FLOOR, CR BUILDING, NO.1, QUEENS ROAD, BENGALURU-560001. …RESPONDENTS (BY SRI. E.I. SANMATHI, ADV.) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE IMPUGNED ORDER DATED 05.04.2022 BEARING DIN NO. ITBA/AST/F/148A/2022-23/1042518067(1) PASSED BY THE 2ND RESPONDENT UNDER SECTION 148A(d) OF THE INCOME TAX ACT, FOR ASSESSMENT YEAR 2015-16 (ANNEXURE-C1) AND ETC. THIS PETITION, COMING ON FOR HEARING ON INTERLOCUTORY APPLICATION, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE SURAJ GOVINDARAJ ORAL ORDER 1. Petitioner is before this Court seeking for following reliefs: i. Quashing the impugned order dated 05.04.2022 bearing DIN & Notice No.ITBA/AST/F/148A/2021- 22/1042518067(1) passed by 2nd respondent under Section 148A(d) of the Income Tax Act, - 3 - HC-KAR NC: 2025:KHC:25176 WP No. 12797 of 2024 1961 for the Assessment Year 2015-16 (Annexure 'C-1'); ii. Quashing the impugned notice dated 05.04.2022 bearing DIN & Notice No.ITBA/AST/148-1/2022- 23/1042522147(1)issued by 2nd respondent under Section 148 of the Income-Tax Act, 1961, for the Assessment Year 2015-2016 (Annexure 'C2'); iii. Quashing the impugned assessment order dated 27.03.2024 bearing DIN & Notice No.ITBA/AST/S/147/2023-2024/1063506500(1) passed by 1st respondent under Section 147 read with Section 144B of the Income Tax Act, 1961 for the Assessment Year 2015-16 (Annexure 'H-1'); iv. Quashing the impugned computation sheet dated 27.03.2024 bearing DIN & Notice No.ITBA/AST/S/114/2023-2024/1063506535(1) for the Assessment Year 2015-16 (Annexure 'H- 2'); v. Quashing the impugned notice of demand dated 27.03.2024 bearing DIN & Notice No.ITBA/AST/S/156/2023-2024/1063506561(1) issued by respondent No.1 under Section 156 of - 4 - HC-KAR NC: 2025:KHC:25176 WP No. 12797 of 2024 the Income Tax Act, 1961 for the Assessment Year 2015-16 (Annexure 'H-3'); vi. Quashing the impugned notice of penalty dated 27.03.2024 bearing DIN & Notice No.ITBA/PNL/S/271(1)(B)/2023-24/1063506578(1) issued by respondent No.1 under Section 274 read with Section 271(1)(b) of the Income Tax Act, 1961 for the Assessment Year 2015-16 (Annexure 'J'); vii. Quashing the impugned notice of penalty dated 27.03.2024 bearing DIN & Notice No.ITBA/PNL/F/271F/2023-24/1063506580(1) issued by Respondent No.1 under Section 274 read with Section 271F of the Income Tax Act, 1961 for the Assessment Year 2015-16 (Annexure 'K'); viii. Quashing the impugned penalty notice dated 27.03.2024 bearing DIN & Notice No.ITBA/PNL/F/271(1)(c)2022-23/1063506579(1) issued by respondent No.1 under Section 274 read with Section 271(1)(c) of the Income Tax Act, 1961 for the Assessment Year 2015-16 (Annexure 'L') and - 5 - HC-KAR NC: 2025:KHC:25176 WP No. 12797 of 2024 ix. Pass such other or further orders that this Hon'ble Court, may deem fit, in the facts and circumstances of the case, and in the interests of justice and equity. 2. What has been challenged is the impugned order dated 05.04.2022 and subsequent notices and orders passed in respect of Assessment Year 2015-16. 3. Learned counsel for the petitioner submits that the concession offered by Revenue as recorded in Sub Para (f) of Paragraph No.19 of the decision rendered by the Hon'ble Apex Court in the case of Union of India And Others v. Rajeev Bansal 1 would be equally applicable in the present facts of the case wherein it is held that the revenue concedes that for the Assessment Year 2015-16, all notices issued on or after April 1, 2021 will be dropped and the concession is offered therein. 1 reported in (2024) 469 ITR 46 - 6 - HC-KAR NC: 2025:KHC:25176 WP No. 12797 of 2024 4. Sri. E I Sanmathi, learned counsel for respondent Nos.1 and 2 submits that the said concession would be equally applicable to the present facts of the case. 5. As such, I proceed to pass the following: ORDER i. Writ Petition is allowed. ii. Annexure 'C-1', 'C-2', 'H-1', 'H-2', 'H-3', 'Q', 'J'; 'K' and 'L' are hereby quashed. SD/- (SURAJ GOVINDARAJ) JUDGE SSD List No.: 1 Sl No.: 34.8