- 1 - HC-KAR NC: 2025:KHC:37397 WP No. 18201 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 18201 OF 2025 (T-IT) BETWEEN: SHRI. MANGALAPURA DASHARATHY ASHOK NAG S/O M.V. DASHARATHY, AGED ABOUT 39 YEARS, MATHRUSHREE SERVICE STATION, MANGALAPURA, KASABA HOBLI, HN PURA TALUK, MUDALAHIPPE, HASSAN - 573 211 …PETITIONER (BY SRI. LOCHANA S BABU, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD- AND TPS AAYAKAR BHAVAN, 2ND STAGE, VIJAY NAGAR, BELUR ROAD, HASSAN - 573 201 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX-3 BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095 Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37397 WP No. 18201 of 2025 3. THE ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, REP. BY ADDL/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, NEW DELHI - 110 003. …RESPONDENTS (BY SRI. M. THIRUMALLESH, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A) ISSUE A WRIT OF CERTIORARI OR A DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE ISSUED UNDER SECTION 148A(B) OF THE ACT DATED 01.02.2024 OF THE ACT FOR THE AY 2020-21 BY THE RESPONDENT NO. 1 BEARING DIN ITBA/AST/F/148A(SCN)/2023-24/1060395758(1), HEREIN MARKED AS ANNEXURE - A AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN 'B' GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:37397 WP No. 18201 of 2025 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “a) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the notice issued under section 148A(b) of the Act dated 01.02.2024 of the Act for the AY 2020-21 by the Respondent No. 1 bearing DIN herein ITBA/AST/F/148A(SCN)/2023-24/1060395758(1), marked as Annexure - A. b) Issue a Writ of Certiorari or a direction in the nature of a Writ of Certiorari quashing the order passed under section 148A(d) of the Act dated 20.03.2024 for the AY 2020-21 by the Respondent No. 1 bearing DIN ITBA/AST/F/148A/2023- 24/1062981640(1), herein marked as Annexure - A1. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 148 of the Act dated 20.03.2024 for the AY 2020-21 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/148_1/2023- 24/1062982070(1) herein marked as Annexure - A2. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the assessment order dated 23.12.2024 passed under section 147 r.w.s. 144 read with 144B of the Act for the AY 2020-21 by the Respondent No. 3 bearing DINS ITBA/AST/S/147/2024-25/1071505788(1), herein marked as Annexure - A3. - 4 - HC-KAR NC: 2025:KHC:37397 WP No. 18201 of 2025 e) Issue a writ of Certiorarl or direction in the nature of a writ of certiorari quashing the computation sheet dated 23.12.2024 for the AY 2020-21 by the Respondent No. 3 bearing DINS ITBA/AST/S/330/2024-25/1071506398(1), herein marked as Annexure - A4. f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the demand notice dated 23.12.2024 passed under section 156 of the Act for the AY 2020-21 by the Respondent No. 3 bearing DINS ITBA/AST/S/156/2024- 25/1071506816(1), herein marked as Annexure - A5. x) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty show cause notice dated 23.12.2024 issued under section 271AAC(1) of the Act for the AY 2020-21 by the Respondent No. 3 bearing DIN No. ITBA/PNL/S/271AAC(1)/2024-25/1071505882(1), herein as Annexure - A6. xi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 09.06.2025 passed under section 271AAC(1) of the Act for the AY 2020-21 by the Respondent No. 3 bearing DIN ITBA/PNL/F/271AAC(1)/2025- 26/1076844750(1), herein marked as Annexure - A7. g) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Shri Lochana S. Babu, learned counsel appearing for the petitioner and Shri M. Thirumallesh, learned counsel appearing for the respondents. - 5 - HC-KAR NC: 2025:KHC:37397 WP No. 18201 of 2025 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 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:37397 WP No. 18201 of 2025 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE JY List No.: 1 Sl No.: 111