- 1 - HC-KAR NC: 2025:KHC:39281 WP No. 28291 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. 28291 OF 2025 (T-IT) BETWEEN: 1. SHRI AMARANARAYANA SWAMY AGED ABOUT 61 YEARS NO.186, 3RD B CROSS JAKKUR MAIN ROAD BENGALURU - 560 064 …PETITIONER (BY SMT. LOCHANA S. BABU, ADVOCATE) AND: 1. INCOME TAX OFFICER WARD 6 (3) (1) BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU - 560 095. 2. INCOME TAX OFFICER WARD 6 (1)(1) BMTC BUILDING 80 FEET ROAD 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU - 560 095 3. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KARNATAKA AND GOA Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39281 WP No. 28291 of 2025 NO.1, C.R. BUILDING, QUEEN'S ROAD BENGALURU - 560 001 4. ASSESSEMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE REP. BY ADDL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER INCOME TAX DEAPRTMENT MINISTRY OF FINANCE ROOM NO.401, 2ND FLOOR E RAMP JAWAHARAL NEHRU STADIUM NEW DELHI - 110 003 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A) ISSUE A WRIT OF CERTIORARI OR A DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE DATED 23.03.2022 ISSUED UNDER SECTION 148A(b) OF THE ACT FOR THE AY 2015-16 BY THE RESPONDENT NO. 1 BEARING DIN ITBA/AST/F/148A(SCN)/2021-22/1041371614(1), HEREIN MARKED AS ANNEXURE-A. B) ISSUE A WRIT OF CERTIORARI OR A DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE ORDER DATED 31.03.2022 PASSED UNDER SECTION 148A(d) OF THE ACT FOR THE AY 2015-16 BY THE RESPONDENT NO. 1 BEARING DIN ITBA/AST/F/148A/2021- 22/1042303259(1), HEREIN MARKED AS ANNEXURE-A1 AND ETC. - 3 - HC-KAR NC: 2025:KHC:39281 WP No. 28291 of 2025 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 is before this Court, seeking the following prayer: "a) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the notice dated 23.03.2022 issued under section 148A(b) of the Act for the AY 2015-16 by the Respondent No. 1 bearing DIN ITBA/AST/F/14BA(SCN)/2021- 22/1041371614(1), herein marked as Annexure - A. b) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the order dated 31.03.2022 passed under section 148A(d) of the Act for the AY 2015-16 by the Respondent No.1 bearing DIN ITBA/AST/F/148A/2021- 22/1042303259(1), herein marked as Annexure - A1. c) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the notice dated 31.03.2022 issued under section 148 of the Act for the AY 2015-16 by the Respondent No.1 bearing DIN ITBA/AST/S/148_1/2021- 22/1042354591(1), herein marked as Annexure - A2. d) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the reassessment order dated 24.03.2023 passed under section 147 of the Act for the AY 2015-16 by the Respondent No. 2 bearing DIN - 4 - HC-KAR NC: 2025:KHC:39281 WP No. 28291 of 2025 ITBA/AST/S/147/2022-23/1051228800(1), herein marked as Annexure - A3. e) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the penalty show cause notice dated 24.03.2023 issued under section 271(1)(b) of the Act for the AY 2015-16 by the Respondent No. 2 bearing DIN ITBA/PNL/S/271(1)(b)/2022 23/1051237193(1), herein marked as Annexure - A4. f) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the penalty order dated 31.08.2023 passed under section 271(1)(b) of the Act for the AY 2015-16 by the Respondent No. 2 bearing DIN ITBA/PNL/F/271(1)(b)/2023-24/1055610096(1), herein marked as Annexure A5. g) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the penalty show cause notice dated 24.03.2023 Issued under section 271(1)(c) of the Act for the AY 2015-16 by the Respondent No. 2 bearing DIN ITBA/PNL/S/271(1)(c)/2022- 23/1051228890(1), herein marked as Annexure - A6. h) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the penalty order dated 20.09.2023 passed under section 271(1)(c) of the Act for the A.Y. 2015-16 by the Respondent No. 2 bearing DIN ITBA/PNL/F/271(1)(c)/2023-24/1056302122(1), herein marked as Annexure A7. i) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the penalty show cause notice dated 24.03.2023 issued under section 271F of the Act for the AY 2015-16 by Respondent No. 2 bearing DIN ITBA/PNL/S/271F/2022- 23/1051237104(1), herein marked as Annexure A8. - 5 - HC-KAR NC: 2025:KHC:39281 WP No. 28291 of 2025 j) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the penalty order dated 11.08.2023 passed under section 271F of the Act for the AY 2015-16 by the Respondent No. 3 bearing DIN ITBA/PNL/F/271F/2023- 24/1055072723(1), herein marked as Annexure - A9. k) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Smt. Lochana S. Babu, 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: - 6 - HC-KAR NC: 2025:KHC:39281 WP No. 28291 of 2025 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. (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.: 5 Sl No.: 25