- 1 - HC-KAR NC: 2025:KHC:37383 WP No. 13169 of 2023 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. 13169 OF 2023 (T-IT) BETWEEN: MUNISWAMYNAIDU VENU AGED 61 YEARS, S/O MUNISWAMYNAIDU, NO.62, 1ST C MAIN, VIVEKANANDA NAGAR, BANGALORE - 560 085, PAN AAZPV5982H. …PETITIONER (BY SRI. SUDHEENDRA B.R, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE7(1)(1), BANGALORE, ROOM NO.240, 2ND FLOOR, BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BANGALORE - 560 095. 2. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU 2, BENGALURU, 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:37383 WP No. 13169 of 2023 3. CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE,. MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI - 110 002, REP BY ITS CHAIRPERSON. 4. NATIONAL FACELESS ASSESSMENT CENTRE REP BY ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME-TAX/INCOME/TAX OFFICER, INCOME/TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E RAMO, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003. …RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE ORDER UNDER SECTION 148A DATED 29.07.2022 PASSED BY THE DCIT CIRCLE 7(1)(1) BANGALORE IE R-1 WITH DIN AND ORDER NO. ITBA/COM/F/17/2022-23/1044286736(1) FOR THE AY 2017-18 (ANNX-D) AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:37383 WP No. 13169 of 2023 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “(A) Quashing the order under section 148A dated 29.7.2022 passed by the DCIT, Circle 7(1)(1), Bangalore i.e., 1st respondent with DIN & Order No ITBA/COM/F/17/2022-23/1044286736(1) for the AY 2017-18 (Annexure D) (B) Quashing the Notice under section 148 dated 29.7.2022 issued by DCIT, Circle 7(1)(1), Bangalore i.e., 1st respondent for the AY 2017-18 (Annexure E1) (C) Quashing the Assessment order under section 147 rws 144B passed by the Assessment Unit, National Faceless Assessment Centre l.e., 4th respondent dated 27.5.2023 with DIN ITBA/AST/S/147/2023- 24/1053240301(1) for the AY 2017-18 (Annexure L1) (D) Quashing the Computation sheet passed by the Assessment Unit, National Faceless Assessment Centre i.e., 4th respondent dated 27.5.2023 with DIN & Document No ITBA/AST/S/213/2023- 24/1053240368(1) for the AY 2017-18 (Annexure L2) (E) Quashing the Notice of demand under section 156 passed by the Assessment Unit, National Faceless Assessment Centre i.e., 4th respondent dated 27.5.2023 with DIN & Notice No ITBA/AST/S/156/2023-24/1053240339(1) (Annexure L3) (F) Quashing the Notice for Penalty under section 274 read with section 272A(1) (d) issued by the Assessment unit, National Faceless Assessment Centre i.e., 4th respondent dated 27.5.2023 with - 4 - HC-KAR NC: 2025:KHC:37383 WP No. 13169 of 2023 DIN ITBA/PNL/S/272A(1)(d)_FL/2023- 24/1053240058(1) (Annexure L4) (G) Quashing the Notice for Penalty under section 274 read with section 271AAC(1) issued by the Assessment unit, National Faceless Assessment Centre i.e., 4th respondent dated 27.5.2023 with DIN ITBA/PNL/S/271AAC(1)/2023- 24/1053240421(1) (Annexure L5) And (H) Passing such other or further orders as this Honourable High Court may think fit in the facts and circumstances of the case, in the interests of justice and equity." 2. Heard Shri Sudheendra B.R., learned counsel appearing for the petitioner and Shri E.I. Sanmathi, 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: - 5 - HC-KAR NC: 2025:KHC:37383 WP No. 13169 of 2023 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 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE JY List No.: 1 Sl No.: 0 CT: BHK