- 1 - HC-KAR NC: 2025:KHC:37894 WP No. 29838 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.29838 OF 2024 (T-IT) BETWEEN: LATE MRS. NOORUNNISSA BABU REP. BY HER LEGAL REPRESENTATIVE MRS. SHAMEEM BABU, DAUGHTER OF SHRI. N BABU, AGED ABOUT 42 YEARS, NO.96, 3RD CROSS, 7TH BLOCK, KORAMANGALA IND LAYOUT BENGALURU – 560 095. …PETITIONER (BY SRI. SHREEHARI, ADVOCATE) AND: 1. INCOME TAX OFFICER, WARD 5(3)(1) BENGALURU, THE JURISDICTIONAL ASSESSING OFFICER UNDER THE INCOME TAX ACT, 1961, BMTC BUILDING, 80 FT ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095 EMAIL: BANGALORE.IT05.2.1@INCOMETAX.GOV.IN 2. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA AND GOA, BENGALURU, THE SPECIFIED AUTHORITY UNDER SECTION 151 OF THE INCOME TAX ACT, 1961, CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37894 WP No. 29838 of 2024 3. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), A CENTRE DESCRIBED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI – 110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC) 4. ASSESSMENT UNIT, A UNIT CREATED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI – 110 003, REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC) …RESPONDENTS (BY SRI. M. THIRUMALESH., ADVOCATE) THIS W.P. IS FILED UNDER THE ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR ANY OTHER SUITABLE WRIT FOR QUASHING OF THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED NOTICE UNDER SECTION 148A(b) OF THE INCOME TAX ACT, 1961 DATED 23/02/2023 ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2016-17 WHICH BEARS THE DIN VIZ., ITBA/AST/F/148A(SCN)/2022- 23/1050054248(1) AND ENCLOSED AS ANNEXURE C AND ETC THIS PETITION COMING ON FOR PRELIMINARY HEARING THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:37894 WP No. 29838 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “a. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice u/s 148A(b) of the Income Tax Act, 1961 dated 23/02/2023 issued by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/AST/F/148A(SCN)/2022-23/1050054248(1) and enclosed as Annexure C. b. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated order u/s 148A(d) of the Income Tax Act, 1961 dated 16/03/2023 issued by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/AST/F/148A/2022-23/1050843554(1) and enclosed as Annexure D. c. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice u/s 148 of the Income Tax Act, 1961 dated 16/03/2023 issued by the Respondent No. 1 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/AST/S/148_1/2022-23/1050844318(1) and enclosed as Annexure E. d. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated assessment order under section 147 r.w.s 144 r.w.s. 144B of the Income Tax Act, 1961 dated 05/02/2024 passed by - 4 - HC-KAR NC: 2025:KHC:37894 WP No. 29838 of 2024 the Respondent No. 4 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/AST/S/147/2023-24/1060506382(1) and enclosed as Annexure L1. e. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice of demand under section 156 of the Income Tax Act, 1961 dated 05/02/2024 issued by the Respondent No. 4 for the Assessment Year 2016-17 which bears the DIN viz. ITBA/AST/S/156/2023-24/1060506525(1) and enclosed as Annexure L2. f. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated computation sheet dated 05/02/2024 issued by the Respondent No. 4 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/AST/S/114/2023- 24/1060506550(1) and enclosed as Annexure L3. g. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated order under section 271(1)(b) of the Income-tax Act, 1961 dated 09/07/2024 issued by the Respondent No. 4 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/PNL/F/271(1)(b)/2024-25/1066515907(1) and enclosed as Annexure M1. h. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice of demand under section 156 of the Income-tax Act, 1961 dated 09/07/2024 issued by the Respondent No. 4 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/PNL/S/156/2024- 25/1066513477(1) and enclosed as Annexure M2. i. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated order under section 271F of the Income-tax Act, 1961 dated - 5 - HC-KAR NC: 2025:KHC:37894 WP No. 29838 of 2024 06/08/2024 issued by the Respondent No. 4 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/PNL/F/271F/2024-25/1067375191(1) and enclosed as Annexure N1. j. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice of demand under 156 of the Income-tax Act, 1961 dated 06/08/2024 issued by the Respondent No. 4 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/PNL/S/156/2024-25/1067375171(1) and enclosed as Annexure N2. k. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated order under section 271(1)(c) of the Income-tax Act, 1961 dated 07/08/2024 issued by the Respondent No. 4 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/PNL/F/271(1)(c)/2024-25/1067418693(1) and enclosed as Annexure P1. l. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice of demand under 156 of the Income-tax Act, 1961 dated 07/08/2024 issued by the Respondent No. 4 for the Assessment Year 2016-17 which bears the DIN viz., ITBA/PNL/S/156/2024-25/1067419092(1) and enclosed as Annexure P2. m. Grant such other reliefs as this Hon'ble Court deems fit in this matter including but not limited to COSTS OF THIS PETITION.” 2. Heard Sri.Shreehari, learned counsel for the petitioner, Sri.M.Thirumalesh, learned counsel for the respondents. - 6 - HC-KAR NC: 2025:KHC:37894 WP No. 29838 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. - 7 - HC-KAR NC: 2025:KHC:37894 WP No. 29838 of 2024 (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.: 1 Sl No.: 404