- 1 - HC-KAR NC: 2025:KHC:36490 WP No. 11487 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28TH DAY OF AUGUST, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 11487 OF 2024 (T-IT) BETWEEN: M/S MAITRI TRUST A PRIVATE DISCRETIONARY TRUST ESTABLISHED UNDER THE INDIAN TRUSTS ACT, 1882 REPRESENTED BY ITS TRUSTEE, M/S. VISTRA ITCL (INDIA) LTD., REPRESENTED BY ITS AUTHORISED SIGNATORY /ASSISTANT MANAGER SRI. PALASH SINGH, SON OF SRI. PRAKASH SINGH, AGED ABOUT 33 YEARS, NO. 23 NADATHUR PLACE, 8TH MAIN, 3RD BLOCK, JAYANAGAR, BENGALURU 560 011. …PETITIONER (BY SRI. MADHUSUDHAN U A., ADVOCATE) AND: 1. ASSESSMENT UNIT INCOME TAX DEPARTMENT Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:36490 WP No. 11487 of 2024 NATIONAL FACELESS ASSESSMENT CENTRE, MINISTRY OF FINANCE, ROOM NO. 401 2ND FLOOR, E RAMP, JAWARLAL NEHRU STADIUM, DELHI 110 003. 2. THE ASSISTANT COMMISSIONER OF INCOME CIRCLE - 7(1)(1), BENGALURU BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU 560 095. …RESPONDENTS (BY SRI. SANMATHI E I., ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO QUASH THE ASSESSMENT ORDER DATED 26/03/2024 PASSED UNDER SECTION 147 RWS 144B OF THE ACT FOR THE ASSESSMENT YEAR 2018-19 BY THE R1 BEARING DIN NO. ITBA/AST/S/147/2023-24/1063411034(1) HEREIN MARKED AS ANNEXURE-A1 AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:36490 WP No. 11487 of 2024 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 direction in the nature of a writ of certiorari quashing the assessment order dated 26.03.2024 passed under section 147 r.w.s 144B of the Act for the assessment year 2018-19 by the Respondent No.1 bearing DIN No. ITBA/AST/S/147/2023-24/1063411034(1) herein marked as Annexure - A1. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 26.03.2024 for the assessment year 2018-19 issued by the Respondent No.1 bearing DIN & Document No. ITBA/AST/S/185/2023- 24/1063411146(1) herein marked as Annexure - A2. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand issued under section 156 of the Act dated 26.03.2024 for the assessment year 2018-19 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/156/2023-24/1063411111(1) herein marked as Annexure - A3. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 26.03.2024 issued under section 274 r.w.s 271AAC(1) of the Act for the assessment year 2018-19 by the Respondent No.1 bearing DIN No. ITBA/PNL/S/271AAC(1)/2023-24/1063411139(1) herein marked as Annexure - A4. e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated - 4 - HC-KAR NC: 2025:KHC:36490 WP No. 11487 of 2024 14.03.2022 issued under section 148A(b) of the Act for the assessment year 2018-19 by the Respondent No.2 bearing DIN & Notice No. ITBA/AST/F/148A(SCN)/2021-22/1040692344(1) herein marked as Annexure - B1. f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 07.04.2022 passed under section 148A(d) of the Act for the assessment year 2018-19 by the Respondent No.2 bearing DIN & Notice No.ITBA/AST/F/148A/2022-23/1042635772(1) herein marked as Annexure - B2. g) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 07.04.2022 issued under section 148 of the Act for the assessment year 2018-19 by the Respondent No.2 bearing DIN & Notice No. ITBA/AST/S/148_1/2022-23/1042635946(1) herein marked as Annexure - B3. h) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 31.05.2023 issued under section 143(2) of the Act for the assessment year 2018-19 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/F/143(2)_5/2023-24/1053353269(1) herein marked as Annexure - С. i) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri Madhusudhan U.A., learned counsel for the petitioner and Sri M. Thirumalesh, learned counsel for the respondents. - 5 - HC-KAR NC: 2025:KHC:36490 WP No. 11487 of 2024 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. (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 - 6 - HC-KAR NC: 2025:KHC:36490 WP No. 11487 of 2024 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 369