- 1 - HC-KAR NC: 2025:KHC:39223 WP No. 3436 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. 3436 OF 2024 (T-IT) BETWEEN: SRI. KESHAVA. C S/O. SHRI. P. RAMAIAH, AGED ABOUT 52 YEARS, NO.31, SRIRAMNAGARI, 3RD CROSS, HAL POST, MURGESHPALYA, BANGALORE-560 017, PAN: ARNPK4125C, PREVIOUSLY AT: KESHAVA. C, F31 SRIRAM NAGARI F LANE, 3RD CROSS, HAL POST, BANGALORE EAST, BANGALORE-560077. …PETITIONER (BY SRI. RAVI SHANKAR S.V, ADVOCATE) AND: 1. THE INCOME TAX OFFICER, WARD-4(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE-560 095. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39223 WP No. 3436 of 2024 2. 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. 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 2, THE OFFICE OF THE PRINCIPAL COMMISSIONER OF INCOME TAX, KORAMANGALA, BANGALORE-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 QUASH THE NOTICE U/S 148A(b) OF THE ACT DATED 15.03.2022 BEARING DIN NO. ITBA/AST/F/148A(SCN)/2021- 22/1040752853(1) ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2018-19 HEREIN MARKED AS ANNEXURE-A AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39223 WP No. 3436 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “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 15/03/2022 bearing DIN No. ITBA/AST/F/148A(SCN)/2021-22/1040752853(1) issued by the Respondent No.1 for the assessment year 2018- 19 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 148A(d) of the Act dated 29/03/2022 bearing DIN No. ITBA/AST/F/148A/2021-22/1041936054(1) issued by the Respondent No.1 for the assessment year 2018-19 herein marked as Annexure - A1. iii) 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 30/03/2022 bearing DIN No. ITBA/AST/S/148_1/2021-22/1042037229(1), issued by the Respondent No.1 for the assessment year 2018- 19 herein marked as Annexure - A2. iv) 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 dated 09/03/2023 bearing DIN: ITBA/AST/S/147/2022-23/1050564744(1) issued by the Respondent No. 2 for the assessment year 2018-19 herein marked as Annexure - A3. v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order u/s 270A of the Act dated 29/09/2023 22023 bearing DIN No.ITBA/PNL/F/270A/2023-24/1056657936(1) by the - 4 - HC-KAR NC: 2025:KHC:39223 WP No. 3436 of 2024 Respondent No. 2 for the assessment year 2018-19 herein marked as Annexure - A4. vi) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri Ravi Shankar S.V, 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 show cause notice 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:39223 WP No. 3436 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 CBC List No.: 2 Sl No.: 8