- 1 - HC-KAR NC: 2025:KHC:43297 WP No. 32445 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 29TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 32445 OF 2025 (T-IT) BETWEEN: 1. MR. PRAVEEN KUMAR PROPRIETOR, AGED ABOUT 46 YEARS M/S. ARIHANT STEEL HAVING OFFICE AT NO.222/6, K.H. RANGANATHA COLONY, OPP. BHEL, MYSORE ROAD, BENGALURU - 560 039. …PETITIONER (BY SRI. BHARATH KUMAR V., ADVOCATE) AND: 1. UNION OF INDIA THROUGH PRINCIPAL SECRETARY, MINISTRY OF FINANCE, DEPARTMENT OF REVENUE ROOM NO.66-A, NORTH BLOCK NEW DELHI - 110 001 2. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2(4) BLR, HAVING OFFICE AT CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001. …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE FOR R1 AND R2) Digitally signed by SHARADAVANI B Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:43297 WP No. 32445 of 2025 THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE NOTICE DATED 06.12.2022 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A (SCN)/2022-23/1047818813(1) ISSUED BY THE RESPONDENT NO. 2 UNDER SECTION 148A(B) OF THE INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2020-21 (ANNEXURE A). THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this Petition, petitioner seeks the following reliefs: "WHEREFORE, it is prayed that this Hon'ble Court may be pleased to: a. Issue a writ order of direction in the nature of certiorari or any other appropriate writ quashing the notice dated 06.12.2022 bearing DIN & Notice No. ITBA/AST/F/148A (SCN)/2022-23/1047818813(1) issued by the Respondent No. 2 under Section 148A(b) of the Income Tax Act, 1961 for the Assessment Year 2020-21 (Annexure A); b. Issue a writ order of direction in the nature of certiorari or any other appropriate writ quashing the notice dated 25.01.2023 bearing DIN & Notice No. ITBA/AST/F/148A (SCN)/2022-23/1049094210(1) issued by the Respondent No. 2 under Section 148A(b) of the Income Tax Act, 1961 for the Assessment Year 2020-21 (Annexure A1); c. Issue a writ order of direction in the nature of certiorari or any other appropriate writ quashing the notice dated 31.01.2023 bearing DIN & Notice No. ITBA/AST/F/148A (SCN)/2022-23/1049283013(1) issued by the Respondent No. 2 under Section 148A(b) of the Income Tax Act, 1961 for the Assessment Year 2020-21 (Annexure A2); d. Issue a writ, order of direction in the nature of certiorari or any other appropriate writ quashing the - 3 - HC-KAR NC: 2025:KHC:43297 WP No. 32445 of 2025 notice dated 17.03.2023 bearing DIN & Notice No. ITBA/AST/S/148_1/2022-23/1050879921(1) issued by the Respondent No. 2 under Section 148 of the Income Tax Act, 1961 for the Assessment Year 2020-21 (Annexure B). e. Grant such other relief that this Hon'ble Court may deem fit in the facts of the present matter." 2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitioner invited my attention to the order of a Co- ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order. - 4 - HC-KAR NC: 2025:KHC:43297 WP No. 32445 of 2025 4. Per contra, learned counsel for the respondents submits that there is no merit in the petition and that the same is liable to be dismissed. 5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under: "13. I, therefore, pass the following: O R D E R (i) The impugned show cause notices 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 these cases would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. - 5 - HC-KAR NC: 2025:KHC:43297 WP No. 32445 of 2025 (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of these petitions would become necessary." 6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of co-ordinate Bench of this Court in Ramachandra Reddy's case (supra). 7. In the result, I pass the following: ORDER (i) The petition is allowed and disposed of in terms of the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025. (ii)The impugned show cause notices and consequential orders, notices etc., at Annexures- A, A1, A2, B dated 06.12.2022, 25.01.2023, 31.01.2023 and 17.03.2023 respectively are hereby quashed. - 6 - HC-KAR NC: 2025:KHC:43297 WP No. 32445 of 2025 (iii) Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, subsequent to disposal of the matters pending before the Apex Court and all rival contentions between the parties in this regard are kept open and no opinion is expressed on the same. Sd/- (S.R.KRISHNA KUMAR) JUDGE BSV CT-SG List No.: 1 Sl No.: 21