- 1 - HC-KAR NC: 2025:KHC:39694 WP No. 25276 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. 25276 OF 2024 (T-IT) BETWEEN: RINKU DESHAPANDE W/O SRI NILIESH R.DESHPANDE AGED ABOUT 49 YEARS NO.123, TOWER-4 PEBBLE BAY APARTMENTS 1ST MAIN, RMV 2ND STAGE DOLLARS COLONY BENGALURU – 560 094 KARNATAKA. …PETITIONER (BY SRI VENKATESH G., ADVOCATE) AND: 1. THE PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU-1 BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU – 560 095. 2. THE INCOME-TAX OFFICER WARD 6(3)(1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39694 WP No. 25276 of 2024 BENGALURU – 560 095 KARNATAKA. 3. THE ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE REPRESENTED BY ADDITIONAL / JOINT/ DEPUTY/ ASSISTANT COMMISSIONER OF INCOME-TAX/ INCOME TAX OFFICER INCOME TAX DEPARTMENT MINISTRY OF FINANCE ROOM NO.401, 2ND FLOOR, E-RAMP JAWAHARLAL NEHRU STADIUM 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 I) QUASHING THE NOTICE DATED 31.03.2022 ISSUED U/S 148 OF THE INCOME TAX ACT, 1961 BEARING DIN AND NOTICE NO. ITBA/AST/S/148_1/2021-22/1042245018(1) BY THE RESPONDENT NO. 2 FOR THE ASSESSMENT YEAR 2015-16 HEREIN MARKED AS ANNEXURE-A1; II) QUASHING THE SHOW CAUSE NOTICE ISSUED U/S 148A(b) DATED 20.03.2022 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2021- 22/1041106218(1) BY THE RESPONDENT NO. 2 FOR THE ASSESSMENT YEAR 2015-16 HEREIN MARKED AS ANNEXURE- A2; III) QUASHING THE ORDER PASSED UNDER SECTION 148A(d) OF THE INCOME TAX ACT, 1961 DATED 30.03.2022 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A/2021- 22/1042192969(1) BY THE RESPONDENT NO. 2 FOR THE - 3 - HC-KAR NC: 2025:KHC:39694 WP No. 25276 of 2024 ASSESSMENT YEAR 2015-16 HEREIN MARKED AS ANNEXURE- A3; IV) QUASHING THE ASSESSMENT ORDER PASSED BY THE RESPONDENT NO.3 UNDER SECTION 147 R.W.S. 144. R.W.S 144B OF THE INCOME-TAX ACT, 1961 DATED 25.03.2023 FOR THE ASSESSMENT YEAR 2015-16 BEARING DIN ITBA/AST/S/147/2022-23/1051316276(1) HEREIN MARKED AS ANNEXURE-B1; V) QUASHING THE COMPUTATION SHEET DATED 25.03.2023 ISSUED BY THE RESPONDENT NO.3 ACCOMPANYING THE ASSESSMENT ORDER PASSED UNDER SECTION 147 R.W.S. 144 R.W.S 144B OF THE INCOME-TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2015-16 BEARING DIN AND DOCUMENT NO ITBA/AST/S/114/2022- 23/1051316340(1) HEREIN MARKED AS ANNEXURE-B2; VI) QUASHING THE NOTICE OF DEMAND ISSUED UNDER SECTION 156 OF THE INCOME-TAX ACT, 1961 DATED 25.03.2023 FOR THE ASSESSMENT YEAR 2015-16 BEARING DIN AND NOTICE NO. ITBA/AST/S/156/2022-23/1051316323(1) HEREIN MARKED AS ANNEXURE-B3; VII) QUASHING THE ORDER OF PENALTY UNDER SECTION 271(1)(c) OF THE INCOME-TAX ACT, 1961 DATED 31.08.2023 FOR THE ASSESSMENT YEAR 2015-16 BEARING DIN ITBA/PNL/F/271(1)(c)/2023- 24/1055642750(1)HEREIN MARKED AS ANNEXURE-C1; VIII) QUASHING THE COMPUTATION SHEET DATED 31.08.2023 ISSUED BY THE RESPONDENT NO.3 ACCOMPANYING THE ORDER OF PENALTY UNDER SECTION 271(1)(c) OF THE INCOME-TAX ACT, 1961 DATED 31.08.2023 FOR THE ASSESSMENT YEAR 2015-16 BEARING DIN ITBA/PNL/S/271(1)(c)/2022-23/1051316395(1) HEREIN - 4 - HC-KAR NC: 2025:KHC:39694 WP No. 25276 of 2024 MARKED AS ANNEXURE-C2; IX) QUASHING THE NOTICE OF DEMAND ISSUED UNDER SECTION 156 OF THE INCOME-TAX ACT, 1961 DATED 31.08.2023 FOR THE ASSESSMENT YEAR 2015-16 BEARING DIN AND NOTICE NO. ITBA/PNL/S/156/2023-24/1055641923(1) HEREIN MARKED AS ANNEXURE-C3; X) QUASHING THE ORDER OF PENALTY UNDER SECTION 271(1)(b) OF THE INCOME-TAX ACT, 1961 DATED 28.08.2023 FOR THE ASSESSMENT YEAR 2015-16 BEARING DIN ITBA/PNL/F/271(1)(b)/2023-24/1055532290(1) HEREIN MARKED AS ANNEXURE-D1; XI) QUASHING THE COMPUTATION SHEET DATED 31.08.2023 ISSUED BY THE RESPONDENT NO.3 ACCOMPANYING THE ORDER OF PENALTY UNDER SECTION 271(1)(b) OF THE INCOME-TAX ACT, 1961 DATED 28.08.2023 FOR THE ASSESSMENT YEAR 2015-16 BEARING DIN ITBA/PNL/F/271(1)(b)/2022-23/1051316394(1) HEREIN MARKED AS ANNEXURE-D2; XII) QUASHING THE NOTICE OF DEMAND ISSUED UNDER SECTION 156 OF THE INCOME-TAX ACT, 1961 DATED 28.08.2023 FOR THE ASSESSMENT YEAR 2015-16 BEARING DIN AND NOTICE NO. ITBA/PNL/S/156/2023-24/1055532088(1) HEREIN MARKED AS ANNEXURE-D3. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 5 - HC-KAR NC: 2025:KHC:39694 WP No. 25276 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of DIN and notices bearing No.ITBA/AST/S/148_1/2021-22/1042245018(1) dated 31.03.2022, ITBA/AST/F/148A(SCN)/2021-22/1041106218(1) dated 20.03.2022, ITBA/AST/S/156/2022-23/1051316323(1) dated 25.03.2023, ITBA/PNL/S/156/2023-24/1055641923(1) dated 31.08.2023, ITBA/PNL/S/156/2023-24/1055532088(1) dated 28.08.2023, computation sheet No.ITBA/AST/S/114/2022-23/1051316340(1) dated 25.03.2023, ITBA/PNL/S/271(1)(c)/2022-23/1051316395(1) dated 31.08.2023 and orders No.ITBA/AST/F/148A/2021- 22/1042192969(1) dated 30.03.2022, ITBA/AST/S/147/2022- 23/1051316276(1) dated 25.03.2023, ITBA/PNL/F/271(1)(c)/2023-24/1055642750(1) dated 31.08.2023, ITBA/PNL/F/271(1)(b)/2023-24/1055532290(1) dated 28.08.2023, ITBA/PNL/F/271(1)(b)/2022- 23/1051316394(1) dated 28.08.2023 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. - 6 - HC-KAR NC: 2025:KHC:39694 WP No. 25276 of 2024 2. Heard Sri Venkatesh G., 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 DIN and notices bearing No. ITBA/AST/S/148_1/2021-22/1042245018(1) dated 31.03.2022, ITBA/AST/F/148A(SCN)/2021- 22/1041106218(1) dated 20.03.2022, ITBA/AST/S/156/2022-23/1051316323(1) dated 25.03.2023, ITBA/PNL/S/156/2023- 24/1055641923(1) dated 31.08.2023, ITBA/PNL/S/156/2023-24/1055532088(1) dated 28.08.2023, computation sheet No.ITBA/AST/S/114/2022-23/1051316340(1) dated 25.03.2023, ITBA/PNL/S/271(1)(c)/2022- - 7 - HC-KAR NC: 2025:KHC:39694 WP No. 25276 of 2024 23/1051316395(1) dated 31.08.2023 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. (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.: 53