- 1 - HC-KAR NC: 2025:KHC:38587 WP No. 13318 of 2025 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.13318 OF 2025 (T-IT) BETWEEN: TRISTAR MOTORS, A PARTNERSHIP FIRM REGISTERED UNDER THE INDIAN PARTNERSHIP ACT, 1932, REPRESENTED BY ITS PARTNER, SHRI. SHARATH REDDY, S/O LATE SRI. C. MUNI REDDY, AGED ABOUT 63 YEARS, NO.370, AMARJYOTHI LAYOUT, KORAMANGALA INTERMEDIARY RING ROAD, DOMLUR, BENGALURU – 560 071, PAN NO: AACFT3531B [SENIOR CITIZENSHIP BENEFIT NOT CLAIMED] …PETITIONER (BY SRI. MADHUSUDHAN U.A., ADVOCATE) AND: 1. THE ASSESSEMENT UNIT INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE MINSITRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E/RAMP, JAWAHARLAL NEHRU STADIUM, NEW DELHI – 110 003. 2. THE ASSISTANT COMMISSIONER OF INCOME-TAX, BENGALURU, CIRCLE (1)(1)(1), BMTC BUILDING, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:38587 WP No. 13318 of 2025 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095. 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095. …RESPONDENTS (BY SRI. Y.V. RAVI RAJ AND SRI. M. DILIP, ADVOCATES) THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE ASSESSMENT ORDER DATED 23.03.2025 PASSED UNDER SECTION 147 R.W.S 144 R.W.S 144B OF THE INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO.1 BEARING DIN NO.ITBA/AST/S/147/2024-25/1074902174(1) HEREIN MARKED AS ANNEXURE-A1 AND ETC. THIS PETITION COMING ON FOR PRELIMINARY HEARING THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:38587 WP No. 13318 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 direction in the nature of a writ of certiorari quashing the assessment order dated 23.03.2025 passed under section 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961 for the assessment year 2020-21 by the Respondent No.1 bearing DIN No. ITBA/AST/S/147/2024-25/1074902174(1) herein marked as Annexure - A1. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 23.03.2025 for assessment year 2020- 21 by the Respondent No.1 bearing DIN No. ITBA/AST/S/530/2024-25/1074902219(1) herein marked as Annexure - A2. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand dated 23.03.2025 issued under section 156 of the Income Tax Act, 1961 for the assessment year 2020-21 by the Respondent No.1 bearing DIN No. ITBA/AST/S/156/2024-25/1074902206(1) herein marked as Annexure - A3. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 18.03.2025 issued under section 274 r.ws 272A(1)(d) of the Income Tax Act, 1961 for the assessment year 2020-21 by the Respondent No.1 bearing DIN No.ITBA/PNL/S/272A(1)(d)_FL/2024-25/1074901967(1) herein marked as Annexure - A4. - 4 - HC-KAR NC: 2025:KHC:38587 WP No. 13318 of 2025 e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 23.03.2025 issued under section 274 r.ws 270A of the Income Tax Act, 1961 for the assessment year 2020-21 by the Respondent No.1 bearing DIN No. ITBA/PNL/S/270A/2024- 25/1074902267(1) herein marked as Annexure - A5. f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 23.03.2025 issued under section 274 r.ws 271B of the Income Tax Act, 1961 for the assessment year 2020-21 by the Respondent No.1 bearing DIN No. ITBA/PNL/S/271B/2024- 25/1074902269(1) herein marked as Annexure - A6. g) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 23.03.2025 issued under section 274 r.ws 271AAC(1) of the Income Tax Act, 1961 for the assessment year 2020-21 by the Respondent No.1 bearing DIN No. ITBA/PNL/S/271AAC(1)/2024-25/1074902268(1) herein marked as Annexure - A7. h) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 28.02.2024 issued under section 148A(b) of the Income Tax Act, 1961 for the assessment year 2020-21 by the Respondent No. 2 bearing DIN No. ITBA/AST/F/148A(SCN)/2023-24/1061691084(1) herein marked as Annexure - B1. i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 06.03.2024 issued under section 148A(b) of the Income Tax Act, 1961 for the assessment year 2020-21 by the Respondent No.2 bearing DIN No. ITBA/AST/F/148A(SCN)/2023-24/1062120137(1) herein marked as Annexure - B2. - 5 - HC-KAR NC: 2025:KHC:38587 WP No. 13318 of 2025 j) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 12.03.2024 issued under section 148A(b) of the Income Tax Act, 1961 for the assessment year 2020-21 by the Respondent No.2 bearing DIN No. ITBA/AST/F/148A(SCN)/2023-24/1062445090(1) herein marked as Annexure - B3. k) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 31.03.2024 passed under section 148A(d) of the Income Tax Act, 1961 for the assessment year 2020-21 by the Respondent No.2 bearing DIN No. ITBA/AST/F/148A/2023-24/1063774307(1) herein marked as Annexure - B4. l) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 31.03.2024 issued under section 148 of the Income Tax Act, 1961 for the assessment year 2020-21 issued by the Respondent No.2 bearing DIN No. ITBA/AST/S/148_1/2023-24/1063774419(1) herein marked as Annexure - B5. m) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri.Madhusudhan U.A, learned counsel for the petitioner, Sri.Y.V. Ravi Raj and Sri.M.Dilip, learned counsels for the respondents. 3. The grounds projected in the subject petition in support of the prayer quoted supra are identical to the ones - 6 - HC-KAR NC: 2025:KHC:38587 WP No. 13318 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 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:38587 WP No. 13318 of 2025 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE CBC List No.: 1 Sl No.: 433