- 1 - HC-KAR NC: 2025:KHC:39300 WP No. 7008 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. 7008 OF 2025 (T-IT) BETWEEN: SHANKARANARAYANA SUDARSHAN SON OF SHANKARANARAYANA AGED ABOUT 58 YEARS NO. 007, VISHWABHARATHI KUTIR OPP. RMC, TUMKUR ROAD, YESHWANTHPUR, BENGALURU - 560 022. …PETITIONER (BY SRI. RAVI SHANKAR S.V, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD -3(3)(1), BENGALURU HMT BHAWAN, NO. 59, BEALRY ROAD, GANGANAGAR BENGALURU - 560 032 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU -3, BMTC BUILDING Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39300 WP No. 7008 of 2025 80 FEET ROAD, 6TH BOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU - 560 095. 3. ASSESMENT UNIT/ INCOME TAX OFFICER NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2ND FLOOR E-RAMP, JAWARLAL NEHRU STADIUM DELHI - 110 003. …RESPONDENTS (BY SRI. M. THIRUMALESH, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE UNSIGNED SANCTION DATED 27.03.2024 ACCORDED UNDER SECTION 151 OF THE ACT FOR THE ASSESSMENT YEAR 2020- 21 BY THE RESPONDENT NO.2 BEARING DIN AND NOTICE NO. ITBA/AST/S/118/2023-24/1063464320(1) HEREIN MARKED AS ANNEXURE-A AND ETC., - 3 - HC-KAR NC: 2025:KHC:39300 WP No. 7008 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 prayers: “a) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the unsigned sanction dated 27.03.2024 accorded under section 151 of the Act for the assessment year 2020-21 by the Respondent No.2 bearing DIN & Notice No. ITBA/AST/S/118/2023-24/1063464320(1) herein marked as Annexure - A. b) 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 28.03.2024 of the Act for the assessment year 2020-21 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/148_1/2023-24/1063527119(1) herein marked as Annexure -A1. c) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." - 4 - HC-KAR NC: 2025:KHC:39300 WP No. 7008 of 2025 2. Heard Shri Ravishankar S.V., learned counsel appearing for the petitioner and Shri M. Thirumalesh, learned counsel appearing for the respondents. 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. - 5 - HC-KAR NC: 2025:KHC:39300 WP No. 7008 of 2025 (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 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE JY List No.: 2 Sl No.: 75 CT: BHK