- 1 - HC-KAR NC: 2025:KHC:37883 WP No. 34388 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.34388 OF 2024 (T-IT) BETWEEN: SRINIVASAN SARAVANAN S/O SRI. SRINIVASAN A, AGED ABOUT 44 YEARS PROPRIETOR OF M/S S P METALS HAVING BUSINESS AT NO.7 & 8, SRIGANDHADA KAVAL, YESHWANTPUR HOBLI, BENGALURU – 560 023 …PETITIONER (BY SRI. SHREEHARI, ADVOCATE) AND: 1. INCOME TAX OFFICER, WARD 6(2)(1) BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095 THE JURISDICTIONAL ASSESSING OFFICER UNDER THE INCOME TAX ACT, 1961 2. PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU - 1, BENGALURU BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095 THE SPECIFIED AUTHORITY/SANCTIONING AUTHORITY UNDER THE INCOME TAX ACT, 1961 Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37883 WP No. 34388 of 2024 3. NATIONAL FACELESS ASSESSMENT CENTRE REP. BY PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX (NEAC), ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 THE AUTHORITY CREATED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961 4. ASSESSMENT UNIT ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 THE ASSESSING OFFICER OF THE FACELESS JURISDICTION 5. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(2)(1), BENGALURU BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095 THE JURISDICTIONAL ASSESSING OFFICER UNDER THE INCOME TAX ACT, 1961 …RESPONDENTS (BY SRI. M THIRUMALESH, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE NOTICE UNDER SECTION 148A(B) OF THE INCOME TAX ACT, 1961 DATED 30.03.2023 BEARING DIN ITBA/AST/F/148A(SCN)/ 2022-23/1051635369(1) ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2019-20 WHICH IS ENCLOSED AS ANNEXURE B1 AND ETC - 3 - HC-KAR NC: 2025:KHC:37883 WP No. 34388 of 2024 THIS PETITION COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP THIS DAY, ORDER WAS MADE THEREIN AS UNDER: 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 writ of certiorari quashing the notice under section 148A(b) of the Income Tax Act, 1961 dated 30.03.2023 bearing DIN ITBA/AST/F/148A(SCN)/ 2022-23/1051635369(1) issued by the Respondent No. 1 for the Assessment Year 2019-20 which is enclosed as Annexure B1. b. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the notice under section 148A(b) of the Income Tax Act, 1961 dated 03.04.2023 bearing DIN ITBA/AST/F/148A(SCN)/ 2023-24/1051858426(1) issued by the Respondent No. 1 for the Assessment Year 2019-20 which is enclosed as Annexure B2. c. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the notice under section 148A(b) of the Income Tax Act, 1961 dated 08.04.2023 bearing DIN ITBA/AST/F/148A(SCN)/ 2023-24/1051936302(1) issued by the Respondent No. 1 for the Assessment Year 2019-20 which is enclosed as Annexure B3. d. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the notice under section 148A(d) of the Income Tax Act, 1961 dated 19.04.2023 bearing DIN No. ITBA/AST/F/148A/ - 4 - HC-KAR NC: 2025:KHC:37883 WP No. 34388 of 2024 2023-24/1052174825(1) issued by the Respondent No. 1 for the Assessment Year 2019-20 which is enclosed as Annexure D1. e. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the notice under section 148 of the Income Tax Act, 1961 dated 19.04.2023 bearing DIN No. ITBA/AST/S/148_1/ 2023-24/1052175228(1) issued by the Respondent No. 1 for the Assessment Year 2019-20 which is enclosed as Annexure D2. f. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the show cause notice dated 28/02/2024 DIN bearing No. ITBA/AST/F/144(SCN)/2023-24/1061632015 Issued by the Respondent No. 4 for the A.Y. 2019-20 which is enclosed as Annexure H. g. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the order of assessment under section 144 r/w 144 r/w 144B of the Act dated 16.03.2024 bearing DIN No. ITBA/AST/S/147/2023-24/1062725827(1) issued by the Respondent No. 4 for the Assessment Year 2019-20 is enclosed as Annexure J1. h. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the notice of demand under section 156 of the Income Tax Act, 1961 dated 16.03.2024 bearing DIN No. ITBA/AST/S/156/2023-24/1062725832(1) issued by the Respondent No. 4 for the Assessment Year 2019-20 which is enclosed as Annexure J2. i. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the computation of income dated 16.03.2024 bearing DIN No. ITBA/AST/S/3/319/2023-24/1062725830(1) issued by the Respondent No. 4 for the Assessment Year 2019-20 which is enclosed as Annexure J3. j. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the notice under section 274 read with section 271AAC of the - 5 - HC-KAR NC: 2025:KHC:37883 WP No. 34388 of 2024 Income Tax Act, 1961, dated 16.03.2023 issued by the Respondent No. 4 for the Assessment Year 2019-20 bearing DIN No. ITBA/PNL/S/271AAC(1)/2023-24/1062725833(1) which is enclosed as Annexure J4. k. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the issue letter dated 10/05/2024 issued by the Respondent No. 5 for the Assessment Year 2019-20 bearing DIN No. ITBA/RCV/F/17/2024-25/1064790063(1) which is enclosed as Annexure L1. l. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the issue letter dated 17/05/2024 issued by the Respondent No. 5 for the Assessment Year 2019-20 bearing DIN No. ITBA/RCV/F/17/2024-25/1064971753(1) which is enclosed as Annexure L2. m. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the issue letter dated 12/06/2024 issued by the Respondent No. 5 for the Assessment Year 2019-20 bearing DIN No. ITBA/RCV/F/17/2024-25/1065609975(1) which is enclosed as Annexure 13. n. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the notice under section 226(3) of the Income Tax Act, 1961 dated 20/06/2024 issued by the Respondent No. 5 for the Assessment Year 2019-20 bearing DIN No. ITBA/RCV/S/226(3)_1/2024-25/1065847740(1) which is enclosed as Annexure L4. o. And pass such other order as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri Shreehari, learned counsel for the petitioner and Sri M. Thirumalesh, learned counsel for the respondents. - 6 - HC-KAR NC: 2025:KHC:37883 WP No. 34388 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 - 7 - HC-KAR NC: 2025:KHC:37883 WP No. 34388 of 2024 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 409