- 1 - HC-KAR NC: 2025:KHC:44267 WP No. 32672 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 3RD DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 32672 OF 2025 (T-IT) BETWEEN: KHASIMSAB S/O. LATE RAJASAB, AGED ABOUT 55 YEARS, NO. 26, MURUKANAKUNTE (KONDENAHALLI) VILLAGE, H. GOLLAHALLI POST, MULBAGAL TALUK-563 131, KOLAR DISTRICT. …PETITIONER (BY SRI. KASHINATH KALMATH, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD-1, NEW EXTENSION, KOLAR-563 101. 2. ASSESSMENT UNIT INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, NEW DELHI-110 001. …RESPONDENTS (BY SRI.E.I.SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR IN THE NATURE OF WRIT OF CERTIORARI THE NOTICE ISSUED U/S.148A(B) OF THE ACT DATED 23.03.2022 FOR THE ASSESSMENT YEAR 2018-19 (ANNEXURE -A) Digitally signed by HEMALATHA A Location: HIGH COURTOF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:44267 WP No. 32672 of 2025 (ITBA/AST/F/148A(SCN)/2021-22/1041388086(1)) ISSUED BY THE 1ST RESPONDENT 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. The Petitioner humbly pray this Hon'ble Court may be pleased to issue a Writ of Certiorari or in the nature of Writ of Certiorari quashing: i. the notice issued u/s. 148A(b) of the Act dated 23.03.2022 for the assessment year 2018-19 (Annexure A) ITBA/AST/F/148A(SCN)/2021-22/1041388086(1)] issued by the 1st Respondent; ii. the Order made u/s 148A(d) of the Act dated 07.04.2022 for the Α.Υ.2018-19 (Annexure B) (TBA/AST/F/148A/2022- 23/1042643714(1)] passed by 1st Respondent; iii. the notice issued u/s.148 of the Act dated 08.04.2022 for the assessment year 2018-2019 (Annexure-C) (ITBA/AST/S/148_1/2022-23/1042661006(1)] issued by the 1st Respondent; iv. quashing the order dated 01.11.2023 made u/s 147 r.w.s. 144 r.w.s 144B of the Act, for the assessment year - 3 - HC-KAR NC: 2025:KHC:44267 WP No. 32672 of 2025 2018-2019 (Annexure D) [ITBA/AST/S/147/2023- 24/1057595196(1)] passed by the 2nd Respondent; V. quashing the order dated 29.03.2024 made u/s 272A(1)(d) of the Act, for the assessment year 2018-2019 (Annexure E) ITBA/PNL/F/272A(1)(d)/2023-24/1063610571 (1)] passed by the 2nd Respondent; vi. quashing the order dated 03.05.2024 made u/s 272A(1)(d) of the Act, for the assessment year 2018-2019 (Annexure E1) ITBA/ PNL/F/272A(1)(d)/2024-25 /1064607125 (1)] passed by the 2nd Respondent; vii. quashing the order dated 09.05.2024 made u/s 271AAC(1) of the Act, for the assessment year 2018-2019 (Annexure E2) ITBA/PNL/F/271AAC(1)/2024-25/ 1064775909(1)) passed by the 2nd Respondent; B. This Hon'ble Court may be pleased to issue such other relief or reliefs as this Hon'ble Court deems fit, in the Petitioner's case, in the interest of justice. 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 - 4 - HC-KAR NC: 2025:KHC:44267 WP No. 32672 of 2025 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. 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. - 5 - HC-KAR NC: 2025:KHC:44267 WP No. 32672 of 2025 (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. (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. - 6 - HC-KAR NC: 2025:KHC:44267 WP No. 32672 of 2025 (ii) The impugned show cause notices and consequential orders, notices etc., at Annexures-A, B, C, D, E, E1 and E2 dated 23.03.2022, 07.04.2022, 08.04.2022, 01.11.2023, 29.03.2024, 03.05.2024 and 09,.05.2024 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 CM List No.: 2 Sl No.: 12