- 1 - HC-KAR NC: 2025:KHC:39706 WP No. 20013 of 2024 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. 20013 OF 2024 (T-IT) BETWEEN: NARAYAN PRAMOD MIC 17 RAGHAVENDRA GAS AGENCIES, MARUTI TEMPLE ROAD, GANGOTHRI LAYOUT, MYSURU – 570 009, KARNATAKA REPRESENTED BY ITS PROPRIETOR SRI NAYARAN PRAMOD AGED ABOUT 52 YEARS PAN NO. APZPP1376C …PETITIONER (BY SRI MALLAHAR RAO, ADVOCATE) AND: 1. THE ASSESSMENT UNIT INCOME TAX DEPARTMENT NATIONAL E-ASSESSMENT CENTRE, INSIDE JAWAHARLAL NEHRU STADIUM, NEW DELHI – 110 001. 2. THE INCOME TAX OFFICER / ASSESSING OFFICER, OFFICE OF THE INCOME TAX OFFICER WARD 1(1), REAC MYSORE, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39706 WP No. 20013 of 2024 MYSURU – 570 008. 3. NATIONAL FACELESS APPEAL CENTRE ROOM NO-245A, NORTH BLOCK NEW DELHI – 110 001. 4. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU - 4, 5TH FLOOR, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BENGALURU – 560 095. …RESPONDENTS (BY SRI M.DILIP, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE IMPUGNED BEST JUDGMENT ASSESSMENT ORDER DTD. 12.03.2024, PASSED BY THE R-2 VIDE DIN NO. ITBA/AST/S/147/2023-24/1062495739(1) ALONG WITH DEMAND NOTICE VIDE DIN NO. ITBA/AST/S/156/2023- 24/1062495797(1) IS HEREWITH ENCLOSED AND PRODUCED AS ANNEXURE-H AND H1; DIRECTION TO THE RESPONDENT AUTHORITIES TO REFRAIN FROM FURTHER PROCEEDINGS AND TAKE SUCH NECESSARY MEASURES/STEPS IN RESPECT OF THE IMPUGNED BEST JUDGMENT ASSESSMENT ORDER DTD 12.3.2024 PASSED BY THE R-2 VIDE DIN NO. ITBA/AST/S/147/2023-24/1062495739(1) ALONG WITH DEMAND NOTICE VIDE DIN NO. ITBA/AST/S/156/2023- 24/1062495797(1) IS HEREWITH ENCLOSED AND PRODUCED AS ANNEXURE-H AND H1; ISSUE WRIT OR PROHIBITION NOT TO PROCEED FURTHER STEPS OR MEASURES OR ANY SUCH KIND OF INITIATIVES PERTAINING TO RECOVERY (S) OVER THE IMPUGNED DEMAND MADE THEREOF; DIRECTING THE RESPONDENT AUTHORITIES TO REFRAIN FROM FURTHER COERCIVE STEPS IN ANY MANNER OF WHATSOEVER IN NATURE, IN ACCORDANCE TO THE IMPUGNED ORDER DTD 12.03.2024, PASSED BY R-2 VIDE DIN NO. ITBA/AST/S/147/2023-24/1062495739(1) ALONG WITH - 3 - HC-KAR NC: 2025:KHC:39706 WP No. 20013 of 2024 DEMAND NOTICE VIDE DIN NO. ITBA/AST/S/156/2023- 24/1062495797(1) IS HEREWITH ENCLOSED AND PRODUCED AS ANNEXURE-H AND H1; ISSUE WRIT OF PROHIBITION, NOT TO PROCEED FURTHER PURSUANT TO ISSUE OF THE PENALTY NOTICES VIDE ANNEXURE-J AT DIN NO. ITBA/PNL/S/271/2023-24/1062495867(1) DTD. 12.03.2024 ANNEXURE-J1 AT DIN NO. ITBA/PNL/F/271A/2024-25 /1065211281(1) DTD. 29.05.2024 AND ANNEXURE-J2 AT DIN NO. ITBA/PNL/F/17/2024-25/1065841529(1) DTD 19.06.2024. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/AST/S/156/2023- 24/1062495797(1) dated 12.03.2024, ITBA/PNL/S/271/2023- 24/1062495867(1) dated 12.03.2024, DIN No.ITBA/PNL/F/270A/2024-25/1065211281(1) dated 29.05.2024, ITBA/PNL/F/17/2024-25/1065841529(1) dated 19.06.2024 and order No.ITBA/AST/S/147/2023- 24/1062495739(1) dated 29.07.2022 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. - 4 - HC-KAR NC: 2025:KHC:39706 WP No. 20013 of 2024 2. Heard Sri Mallahar Rao, learned counsel for the petitioner and Sri M. Dilip, 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 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 notices bearing No. ITBA/AST/S/156/2023-24/1062495797(1) dated 12.03.2024, ITBA/PNL/S/271/2023- 24/1062495867(1) dated 12.03.2024, DIN No. ITBA/PNL/F/270A/2024-25/1065211281(1) dated 29.05.2024, ITBA/PNL/F/17/2024- 25/1065841529(1) dated 19.06.2024 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in this petition would stand quashed. - 5 - HC-KAR NC: 2025:KHC:39706 WP No. 20013 of 2024 (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 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 2 Sl No.: 44