- 1 - HC-KAR NC: 2025:KHC:44755 WP No. 32945 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 5TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 32945 OF 2025 (T-IT) BETWEEN: M/S BRIGHT PACKAGING PRIVATE LIMITED REGISTERED UNDER THE COMPANIES ACT, 1956, 162-B, BAIKAMPADY INDUSTRIAL AREA, JOKATTE B.O, KENJAR, DAKSHINA KANNADA – 575 011 PAN; AAACB8497K REPRESENTED BY MANAGING DIRECTOR OF THE PETITIONER ANKIT BANSAL, AGED 42 YEARS, S/O ANIL KUMAR BANSAL, NO.3-51/170, FLAT NO.A-2101, KADRI-KUNTIKANA ROAD, PLANET SKS, MANGALORE – 575 008. …PETITIONER (BY SRI. RAVI SHANKAR S. V., ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1) AND TPS, C.R BUILDING, N G ROAD, ATTAWARA, MANGALURU – 575 001 2. NATIONAL FACELESS ASSESSMENT CENTRE ADDITIONAL/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, DELHI – 110 003 Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:44755 WP No. 32945 of 2025 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANAJI, EDC COMPLEX, PATTO-PLAZA, PANAJI, GOA – 403 001 4. ADDITIONAL COMMISSIONER OF INCOME TAX RANGE 1 AND FIRST APPELLATE AUTHORITY, MANGALURU, C.R.BUILDING, N.G.ROAD, ATTAWARA MANGALURU – 575 0011 …RESPONDENTS (BY SRI. TIRUMALESH M., ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 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 NOTICE UNDER SECTION 148A(B) OF THE ACT, DATED 10/03/2022 BEARING DIN NO. ITBA/ASTF/148A(SCN)/2021-22/1040555821(1), ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2018-19 HEREIN MARKED AS ANNEXURE – A 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 for the following reliefs:- “(i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148A(b) of the Act, dated 10.03.2022 bearing DIN No. ITBA/AST/F/148A(SCN)/2021-22/1040555821(1), issued by the Respondent No.1 for the assessment year 2018-19 herein marked as Annexure - A. (ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order under section - 3 - HC-KAR NC: 2025:KHC:44755 WP No. 32945 of 2025 148A(d) of the Act, dated 30/03/2022, bearing DIN No. ITBA/AST/F/148A/2021-22/1042049950(1) issued by the Respondent No.1 for the assessment year 2018-19 herein marked as Annexure - A1. (iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under section 148 of the Act dated 30/03/2022 bearing DIN No. ITBA/AST/S/148_1/2021-22/1042072435(1) issued by the Respondent No.1 for the assessment year 2018- 19 herein marked as Annexure - A2. (iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed under section 147 r.w.s. 144, 144B dated 28/03/2023 bearing DIN No.ITBA/AST/S/147/2022- 23/1051538377(1) issued by the Respondent No.2 for the assessment year 2018-19 herein marked as Annexure - A3. (v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice under Section 271AAC(1) of the Act dated 28/03/2023 bearing DIN No. ITBA/PNL/S/271AAC(1)/2022- 23/1051535375(1) issued by the Respondent No.2 for the assessment year 2018-19 herein marked as Annexure - A4. (vi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the sanction issued under section 151 of the Act, dt: 10/03/2022, issued by the - 4 - HC-KAR NC: 2025:KHC:44755 WP No. 32945 of 2025 Respondent No.3 for the assessment year 2018-19 herein marked as Annexure - A5. (vii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the unsigned sanction issued under section 151 of the Act, dt: 30/03/2022, issued by the Respondent No.3 for the assessment year 2018-19 herein marked as Annexure - A6. (viii) To issue Order(s), Directions, Writ(s) or any other relief as this Hon'ble Court deems it fit and proper in the facts and circumstance of the case 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 the present petition deserves to be allowed and disposed of in terms of the said order. - 5 - HC-KAR NC: 2025:KHC:44755 WP No. 32945 of 2025 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. (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. - 6 - HC-KAR NC: 2025:KHC:44755 WP No. 32945 of 2025 (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. (ii) The impugned show cause notices and consequential orders, notices etc., at Annexures-A, A1, A2, A3, A4, A5 and A6 dated 10.03.2022, 30.03.2022, 30.03.2022, 28.03.2023, 28.03.2023, - 7 - HC-KAR NC: 2025:KHC:44755 WP No. 32945 of 2025 10.03.2022 and 30.03.2022 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 BMC List No.: 2 Sl No.: 40