- 1 - HC-KAR NC: 2025:KHC:42329 WP No. 13244 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 23RD DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 13244 OF 2025 (T-IT) BETWEEN: CHINTAMANI NARAYANASWAMY DEVENDRA MANSOOR AGED ABOUT 47 YEARS, S/O LATE NARYANASWAMYA, R/AT NO.15, GOVINDA NILAYAM, 1ST CROSS, RRMR EXTENSION, BANGALORE- 560 027. …PETITIONER (BY MISS ANNIE ANUJA KULLU FOR SRI. JOSEPH ANILKUMAR A., ADVOCATE) AND: 1. THE CHIEF COMMISSIONER OF INCOME TAX, BENGALURU -I INCOME TAX DEPARTMENT, WARD 7(2)(5), BANGALORE BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU- 560 095 2. THE ASSESSING OFFICER INCOME TAX DEPARTMENT WARD 7(2)(5), BANGALORE BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU- 560 095 3. UNION BANK OF INDIA BANGALORE-GIRINAGAR BRANCH REPRESENTED BY ITS BANK MANAGER NO. 182, 5TH MAIN ROAD, Retyped and replaced vide Court order dated 17.02.2026 Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:42329 WP No. 13244 of 2025 AVALAHALLI MAIN ROAD, BANGALORE- 560 085. …RESPONDENTS (BY SRI. E.I.SANMATHI AND SRI.M.DILIP, ADVOCATE FOR R1 AND R2; V/O DTD 05.06.2025, NOTICE TO R3 IS DEFERRED FOR THE PRESENT.) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING ANNEXURE A, ORDER ISSUED UNDER SECTION 147 R/W SECTION 144 AND 144B OF INCOME TAX ACT BEARING DIN ITBA/AST/S/147/2024-25/1074776434(1) DATED 20/03/2025, ISSUED BY R2., AND ETC. 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, petitioner seeks the following reliefs: "Wherefore, the Petitioner humbly prays that this Hon'ble Court may be pleased to a) Issue a Writ of Certiorari quashing Annexure A, Order issued under Section 147 R/w SectionITBA/AST/S/147/2024-25/1074776434(1) dated 20/03/2025, led by Respondent No.2. b) Issue a Writ of Certiorari quashing Annexure B penalty Notice Under Section 274 R/W Section 270A bearing DIN ITBA/PNL/S/270A/2024 25/1074776564(1) dated 20/03/2025, issued by Respondent No.2. c) Issue a Writ of Certiorari quashing Annexure C Demand Notice Under Section 156 bearing DIN ITBA/AST/S/156/2024-25/1074776553(1) dated 20/03/2025, issued by Respondent No.2. - 3 - HC-KAR NC: 2025:KHC:42329 WP No. 13244 of 2025 d) Issue a Writ of Certiorari quashing Annexure D Penalty Notice Under Section 274 R/w Section 271AAC(1) bearing ITBA/PNL/S/271AAC(1)/2024-DIN 25/1074776566(1) dated 20/03/2025, issued by Respondent No-2. e) Issue a Writ of Certiorari quashing Annexure E Penalty Notice Under Section 274 & 271F bearing DIN ITBA/PNL/S/271F/2024-25/1074776574(1) dated 20/03/2025, issued by Respondent No-2. f) Pass any other order or writ as this Hon'ble Court deems fit in the interest of Justice and equity." 2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitioner invited my attention to the order of a Co- ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that - 4 - HC-KAR NC: 2025:KHC:42329 WP No. 13244 of 2025 the present petition deserves to be allowed and disposed of in terms of the said order. 4. Per contra, learned counsel for the respondents submits that there is no merit in the petition and that the same is liable to be dismissed. 5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under: "13. I, therefore, pass the following: O R D E R (i) The impugned show cause notices 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 these cases would stand quashed. - 5 - HC-KAR NC: 2025:KHC:42329 WP No. 13244 of 2025 (ii) Liberty is reserved to the respondents - revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of these petitions would become necessary." 6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of co-ordinate Bench of this Court in Ramachandra Reddy's case (supra). 7. In the result, I pass the following: ORDER i. The petition is allowed and disposed of in terms of the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025. - 6 - HC-KAR NC: 2025:KHC:42329 WP No. 13244 of 2025 ii. The impugned show cause notices and consequential orders, notices etc., at Annexures-A, B, C, D, E dated 20.03.2025 and Annexure – G dated 28.02.2024, all dated 20.03.2025 respectively are hereby quashed. iii. Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, subsequent to disposal of the matters pending before the Apex Court and all rival contentions between the parties in this regard are kept open and no opinion is expressed on the same. Sd/- (S.R.KRISHNA KUMAR) JUDGE BSV List No.: 2 Sl No.: 31