- 1 - HC-KAR NC: 2025:KHC:39260 WP No. 25987 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 25987 OF 2025 (T-IT) BETWEEN: 1. AAROGYA RAKSHA SAMITHI KRISHNA RAJA HOSPITAL ESTABLISHED THROUGH THE ORDER OF GOVERNMENT OF KARNATAKA DATED 2/4/201 ADMINISTRATIVE OFFICE, K.R. HOSPITAL, MYSORE - 570 001 REPRESENTED BY ITS ASSISTANT ADMINISTRATIVE OFFICER SMT. CHANDRAKALA K.M. AGED 53 YEARS, W/O KRISHNA H.S., NO.38, 2ND FLOOR, C-BLOCK, SBM LAYOUT, BOGADI, MYSORE - 560 026. …PETITIONER (BY SRI. RAVI SHANKAR S.V., ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX OFFICER EXEMPTIONS, CIRCLE 1, UNITY BUILDING ANNEXE, MISSION ROAD, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39260 WP No. 25987 of 2025 BANGALORE - 560 027 2. INCOME TAX OFFICER EXEMPTIONS, WARD, MYSORE - 570 008 3. NATIONAL FACELESS ASSESSMENT CENTRE, ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 4. COMMISSIONER OF INCOME TAX (EXEMPTIONS), OFFICE OF THE COMMISSIONER OF INCOME TAX (EXEMPTIONS) UNITY BUILDING ANNEXE, MISSION ROAD, BANGALORE - 560 027 …RESPONDENTS (BY SRI. ARAVIND V. CHAVAN, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO I) QUASHING THE NOTICE UNDER SECTION 148A(B) OF THE ACT DATED 04/01/2024 BEARING DIN NO.ITBA/AST/F/148A(SCN)/2023- 24/1059387523(1) ISSUED BY THE RESPONDENT NO.2 FOR THE ASSESSMENT YEAR 2020-21 HEREIN MARKED AS ANNEXURE - A AND ETC. - 3 - HC-KAR NC: 2025:KHC:39260 WP No. 25987 of 2025 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: “i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under section 148A(b) of the Act dated 04/01/2024 bearing DIN No. ITBA/AST/F/148A(SCN)/2023- 24/1059387523(1) issued by the Respondent No.2 for the assessment year 2020-21 herein marked as Annexure - A. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the unsigned order under Section 151 of the Act dated 21/02/2024 vide ITBA/AST/S/118/2023-24/1061281935(1), passed by the Respondent no.4 for the assessment year 2020-21 herein marked as Annexure - A1. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order under Section 148A(d) of the Act dated 22/02/2024 bearing DIN No. ITBA/AST/F/148A/2023- 24/1061300777(1) passed by the Respondent No.2 for the assessment year 2020-21 herein marked as Annexure-A2. iv) Issue a Writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148 of the Act dated 22/02/2024 bearing DIN No. ITBA/AST/S/148_1/2023- 24/1061301860(1) issued by the Respondent No.2 - 4 - HC-KAR NC: 2025:KHC:39260 WP No. 25987 of 2025 for the assessment year 2020-21 herein marked as Annexure-A3. v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed U/s 147 r.w.s 144B dated 21/03/2025 bearing ITBA/AAAST/S/147/2024-25/1074836050(1) passed by the Respondent No.3 for the assessment year 2020-21 herein marked as Annexure-A4. vi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice issued u/s 274 r.w.s 270A of the Act dated 21/03/2025 bearing DIN No. ITBA/PNL/S/270A/2024-25/1074836209(1) by the Respondent No.3 for the assessment year 2020-21 herein marked as Annexure-A5. vii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice issued u/s 274 r.w.s 272A(1)(d) of the Act dated 21/03/2025 bearing DIN No. ITBA/PNL/S/272A(1)(d)_FL/2024- 25/1074834084(1) by the Respondent No.3 for the assessment year 2020-21 herein marked as Annexure - A6. viii) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Sri Ravishankar S.V., learned counsel for the petitioner and Sri Aravind V. Chavan, 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 - 5 - HC-KAR NC: 2025:KHC:39260 WP No. 25987 of 2025 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 151-A 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 - 6 - HC-KAR NC: 2025:KHC:39260 WP No. 25987 of 2025 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE SJK CT-SG List No.: 12 Sl No.: 2