- 1 - HC-KAR NC: 2025:KHC:34892 WP No. 16055 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. 16055 OF 2024 (T-IT) BETWEEN: 1. RAMASWAMY ADHIMOOLAM AGED 53 YEARS, SON OF SRI. RAMASWAMY NOC-81, PEENYA 3rd STAGE, BENGALURU - 560 058. PRESENTLY RESIDING AT #125A, 3rd CROSS, 3rd MAIN NEAR AYYAPPA TEMPLE PRAKASHANAGAR, SRIRAMPURAM BENGALURU - 560 021. …PETITIONER (BY SRI MADHUSUDHAN U A, ADVOCATE) AND: 1. DEPUTY COMMISIONER/ ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 6(1)(1) , BENGALURU, BMTC BUILDING, 80 FT ROAD, 6th BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA BENGALURU - 560 095. …RESPONDENT (BY SRI Y V RAVI RAJ AND SRI M DILIP, ADVOCATES) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:34892 WP No. 16055 of 2024 THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 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 U/S 148A(B) OF THE INCOME TAX ACT, 1961 DATED 04/02/2023 ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2019-20 WHICH BEARS THE DIN VIZ., ITBA/AST/F/148A(SCN)/2022- 23/1049416266(1) AND ENCLOSED AS ANNEXURE A1 AND 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 17/02/2023 ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2019-20 WHICH BEARS THE DIN VIZ., ITBA/AST/F/148A(SCN)/2022- 23/1049885578(1) AND ENCLOSED AS ANNEXURE A3 AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:34892 WP No. 16055 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 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 04/02/2023 issued by the Respondent No.1 for the Assessment Year 2019-20 which bears the DIN viz., ITBA/AST/F/148A(SCN)/2022-23/1049416266(1) and enclosed as Annexure A1. b. 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 17/02/2023 issued by the Respondent No. 1 for the Assessment Year 2019-20 which bears the DIN viz., ITBA/AST/F/148A(SCN)/2022-23/1049885578(1) and enclosed as Annexure A3. c. 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 2019-20 which bears the DIN viz., ITBA/AST/F/148A/2022-23/1050832609(1) and enclosed as Annexure B. d. 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 2019-20 which bears the DIN viz., ITBA/AST/S/148_1/2022-23/1050832792(1) and enclosed as Annexure C. - 4 - HC-KAR NC: 2025:KHC:34892 WP No. 16055 of 2024 e. 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 of the Income Tax Act, 1961 dated 27/02/2024 passed by the Respondent No. 3 for the Assessment Year 2019-20 which bears the DIN viz., ITBA/AST/S/147/2023- 24/1061574615(1) and enclosed as Annexure J1. f. 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 27/02/2024 issued by the Respondent No. 3 for the Assessment Year 2019-20 which bears the DIN viz ITBA/AST/S/156/2023-24/1061574722(1) and enclosed as Annexure J2. g. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated computation of income dated 27/02/2024 issued by the Respondent No. 3 for the Assessment Year 2019-20 which bears the DIN viz ITBA/AST/S/319/2023-24/1061574775(1) and enclosed as Annexure J3. h. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice for penalty under section 274 r.w.s 271AAC(1) of the Income- tax Act, 1961 dated 27/02/2024 issued by the Respondent No. 3 for the Assessment Year 2019-20 which bears the DIN viz and ITBA/PNL/S/271AAC(1)/2023-24/1061574733(1) and enclosed as Annexure K1. i. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice for penalty under section 274 r.w.s 272A(1)(d) of the Income- tax Act, 1961 dated 27/02/2024 issued by the Respondent No. 3 for the Assessment Year 2019-20 which bears the DIN viz - 5 - HC-KAR NC: 2025:KHC:34892 WP No. 16055 of 2024 ITBA/PNL/S/272A(1)(d)_FL/2023-24/1061572955 (1) and enclosed as Annexure K2. j. 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 Madhusudhan U.A., learned counsel for the petitioner, Sri Y.V.Ravi Raj and Sri M. Dilip, learned counsel for the respondents. 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. - 6 - HC-KAR NC: 2025:KHC:34892 WP No. 16055 of 2024 (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 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 378 CT.SM