- 1 - HC-KAR NC: 2025:KHC:47831 WP No. 12259 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. 12259 OF 2025 (T-IT) BETWEEN: SRI PADARTHI SRINIVASULU AGED ABOUT 37 YEARS, S/O P.VENKATESHWARULU NO. 17/18 PLOT NO. 102, 1ST FLOOR, 7TH MAIN, MATHAS HOSPITAL RD, SUBRAMANYAPURA POST, UTTARHALLI VASANTHAPURA, BENGALURU- 560 061. ALSO AT HOUSE NO. 164/229 C/O P SATYANARAYANA BALAVENKATA SWAMY STREET KAMBLI BAZAR, 1ST CROSS BELLARY- 563 101. …PETITIONER (BY SRI. SHIVSHANKER., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF OF INCOME TAX- CENTRAL CIRCLE 2(3) CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU-560 001. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) BMTC, BULIDING 6TH BLOCK, 80 FEET ROAD Digitally signed by SHARADAVANI B Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:47831 WP No. 12259 of 2025 KORAMANGALA BENGLAURU 560095 …RESPONDENTS (BY SRI. M.DILIP., ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH OF THE ORDER DATED 29.03.2024 BEARING NO. ITBA/AST/S/118/2023-24/1063603983(1) PASSED BY THE IST RESPONDENT (ANNEXURE-B) UNDER SECTION 151 OF THE ACT FOR THE ASSESSMENT YEAR 2020-21., AND ETC. 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, the petitioner seeks the following reliefs: “(a) Quashing of the order dated 29.03.2024 bearing ITBA/AST/S/118/2023-24/106360363(1) passed by the 1st Respondent (Annexure B) under Section 151 of the Act for the assessment year 2020-21; (b) Quashing of the order dated 28.06.2024 bearing No.ITBA/AST/S/61/2024-25/1066214192(1) passed by the 1st Respondent (Annexure C) under Section-144B of the Act for the assessment year 2020-21; (c) Quashing of the order dated 08.07.2024 bearing No ITBA/AST/F/143(2)/5/2024-25/1066489593(1) passed by the 1st Respondent (Annexure D) under - 3 - HC-KAR NC: 2025:KHC:47831 WP No. 12259 of 2025 Section 143(2) read with Sec 147 of the Act for the assessment year 2020-21; (d) Quashing of the order dated 14.08.2024 bearing No. ITBA/AST/F/142(1)/2024-25/1067623860(1) passed by the 1st Respondent (Annexure E) under Section 142(1) Act for the assessment year 2020- 21; (e) Quashing of the order dated 25.03.2024 bearing No. ITBA/AST/S/147/2024-25/1075000891(1) passed by the Ist Respondent (Annexure F) under Section 147 read with sec 144B Act for the assessment year 2020-21; (f) Quashing of the order dated 14.01.2025 bearing: No ITBA/ABT/F/17/2024-25/1072156607(1) passed by the 1st Respondent (Annexure E) under Section 148 Act for the assessment year 2020-21; (g) Quashing of the order dated 19.02.2025 touring The ITBA/AST/P/147(SCN)/2024-25/107347972211) passed by the first Respondent (Annexure-H) for the assessment year 2020-21, (h) Quashing of the Computation sheet dated 25.03.2025 bearing No. ITBA/AST/S/330/20-24 passed by the first respondent marked at Annexure-K; (j) Quashing of the Notice for penalty dated 25.03.2025 bearing No ITBA/PNL/S/271AAC (1)/2024- 25/1075001639(1) passed by the Ist Respondent (Annexure L) under Section 274 read with 271AAC (1) of Act for the assessment year 2020-21, (k) Quashing of the Notice of demand under section 156 of the IT dated 25.3.2025 bearing No ITBA/AST/S/156/2024-25/1075001032(1) Passed by the 1st respondent marked at Annexure-M. - 4 - HC-KAR NC: 2025:KHC:47831 WP No. 12259 of 2025 (i) Pass such other or further orders as this Hon'ble Court may deem fit in the facts and circumstances of the case in the Interests of justice and equity.” 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. 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 - HC-KAR NC: 2025:KHC:47831 WP No. 12259 of 2025 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. - 6 - HC-KAR NC: 2025:KHC:47831 WP No. 12259 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- B, C, D, E, F, H, K, L, M, dated 29.03.2024, 28.06.2024, 08.07.2024, 14.08.2024, - 7 - HC-KAR NC: 2025:KHC:47831 WP No. 12259 of 2025 25.03.2024, 14.01.2025, 19.02.2025 25.03.2025, 25.03.2025, 25.3.2025 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 JJ List No.: 3 Sl No.: 6