- 1 - HC-KAR NC: 2025:KHC:47965 WP No. 21864 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 19TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 21864 OF 2025 (T-IT) BETWEEN: RUKMINI VENKATAPPA W/O. RAMAKRISHNA C T, (AGED ABOUT 69 YEARS) NO 16, 7TH CROSS, MAGADI ROAD, CHOLUR PALYA, BANGALORE NORTH - 560 023. …PETITIONER (BY SRI. PRAKASH D, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD 3(1)(1) BMTC BUILDING, 80FT ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU 560 095. 2. NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NEW DELHI - 110 001. …RESPONDENTS (BY SRI. M. THIRUMALESH, ADVOCATE) THIS W.P IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH ORDER DTD 29.03.2024 PASSED UNDER SEC 148A(d) OF THE INCOME TAX ACT, 1961 AT ANNX-B IN DIN ITBA/AST/F/148A/23-24/1063595168(1) BY R-1. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:47965 WP No. 21864 of 2025 CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks fro the following reliefs:- “ (A) Issue a Writ of Certiorari by quashing order dated: 29.03.2024 passed under Section 148A(d) of the Income Tax Act, 1961 at Annexure-“B” in DIN: ITBA/AST/F/148A/2023-24/1063595168(1) by Respondent No.1. (B) Quash the notice under Section 148 dated: 29.03.2024 Annexure-“C” in DIN: ITBA/AST/F/148/_1/2023- 24/1063595416(1) issued by Respondent No.1. (c) Quash the consequential Assessment Order dated: 02.01.2025 passed under Section 147 r/w Sections 144 and 144B at Annexure- “E” in DIN: ITBA/AST/S/147/2024-25/1071806879(1) passed by Respondent No.2; (D) Quash demand notice dated: 02.01.2025 Annexure- “F” in DIN: ITBA/AST/S/156/2024- 25/1071807127(1), as being contrary to law and arbitrary issued by Respondent No.1; (E) Hold and declare that the entire reassessment proceedings initiated under Section 148A culminating in the impugned reassessment and demand are bad in law and without jurisdiction. (F) Hold that the proceedings initiated under Section 148 vide notice dated: 29.03.2024 at Annexure- “C” in DIN: ITBA/AST/F/148_1/2023-24/1063595416(1) - 3 - HC-KAR NC: 2025:KHC:47965 WP No. 21864 of 2025 Respondent No.1 is barred by limitation under Section 149 of the Income Tax Act, 1961. (G) Pass any other order or give any other direction as this Honorable Court deems fit and proper in the circumstances of the case.” 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 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. 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 - 4 - HC-KAR NC: 2025:KHC:47965 WP No. 21864 of 2025 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. (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 - 5 - HC-KAR NC: 2025:KHC:47965 WP No. 21864 of 2025 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 notices and consequential orders, notices etc., at Annexures- B, C, E, F dated 29.03.2024, 29.03.2024, 02.01.2025 and 02.01.2025 respectively are hereby quashed. (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 Srl.