- 1 - HC-KAR NC: 2025:KHC:44035 WP No. 32743 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. 32743 OF 2025 (T-IT) BETWEEN: PRIMARY AGRICULTURE CO-OPERATIVE SOCIETY LTD., *TALAKERE POST, KASABA HOBLI TURUVEKERE TALUK, TUMKUR DISTRICT-572 224, REP. BY ITS CHIEF EXECUTIVE OFFICER, * SRI. T. SHASHIDHARA THE SOCIETY IS REGITERED UNDER CO-OPERATIVE SOCIETY ACT. …PETITIONER (BY SRI. NAGARAJA S.,ADVOCATE) AND: 1. THE INCOME TAX OFFICER, WARD NO.1, TIPTUR, THE JURISDICTIONAL ASSESSING OFFICER, UNDER INCOME TAX ACT, 1961, JAYADEVA COMPLEX, TIPTUR, TUMKUR-572201. 2. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-2, THE SPECIFIED AUTHORITY UNDER SECTION 151 OF THE INCOME TAX ACT, 1961, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU-560095. 3. NATIONAL FACELESS, ASSESSMENT CENTRE (NFAC), A CENTRE DESCRIBED UNDER SECTION, 144B OF THE INCOME TAX ACT, 1961, 2ND FLOOR, E-RAMP, * Corrected vide Court Order dated: 27.04.2026. Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:44035 WP No. 32743 of 2025 JAWAHARLAL NEHRU STADIUM, DELHI-110003, 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-110003, REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC) …RESPONDENTS (BY SRI M DILIP AND SRI E I SANMATHI, ADVS. FOR R1 TO R4) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A) QUASH THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED NOTICE UNDER SECTION 221(1) OF THE INCOME TAX ACT, 1961 DATED 04/09/2025 BEARING DIN AND NOTICE NO.ITBA/RVC/S/2021/2025-26/1080341715(1) ISSUED BY THE R1 AS PER ANNX-C. B) CONSEQUENTLY, ISSUE A WRIT OF MANDAMUS DIRECTING THE R1 TO PROVIDE AN OPPORTUNITY TO THE PETITIONER TO SUBMIT ITS REPLY/ RESPONSE. THIS PETITION, COMING ON FOR ORDERS, 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) To issue a Writ of Certiorari, or any other writ or order or direction to quash the digitally signed and electronically communicated notice under section 221(1) of the INCOME TAX ACT, 1961 dated 04.09.2025 bearing and notice No.ITBA/RVC/S/2021/2025-26/1080341715(1) issued by respondent No.1 as per Annexure-'C'. - 3 - HC-KAR NC: 2025:KHC:44035 WP No. 32743 of 2025 b) Consequently, issue a Writ of Mandamus directing the respondent to provide an opportunity to the petitioner to submit its reply/response. c) Grant such other reliefs as this Hon'ble Court deems fit to grant in the and circumstances of the case in the interest of justice and equity.” 2. After arguing the matter for sometime, Learned counsel for the petitioner submitted that the petition may be disposed of as withdrawn reserving liberty in favour of the petitioner to take recourse to such remedies as available in law including approaching the respondent authorities as well as subsequently filing a writ petition before this Court. 3. Submission is placed on record. 4. Petition stands disposed of as withdrawn reserving liberty in favour of the petitioner to take recourse to such remedy as available in law, including approaching the respondents as well as approaching this Court if the occasion so arises. 5.Liberty is also reserved in favour of the petitioner to submit his reply to the impugned notice at Annexure C dated 04.09.2025 - 4 - HC-KAR NC: 2025:KHC:44035 WP No. 32743 of 2025 and if the petitioner submits such a reply, the respondent shall consider the same and proceed further in accordance with law. Sd/- (S.R.KRISHNA KUMAR) JUDGE CM List No.: 2 Sl No.: 13