- 1 - HC-KAR NC: 2025:KHC:39317 WP No. 4377 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. 4377 OF 2025 (T-IT) BETWEEN: MUDIGUNDAM SRINIVASAMURTHY MANJUNATH SON OF M. C. SRINIVASA MURTHY, AGED ABOUT 42 YEARS, 1296, MIG, 6TH CROSS, NEAR PUJA MARKETING, VIVEKANANDA NAGAR, MYSURU- 570 023. …PETITIONER (BY SMT. LOCHANA S BABU, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1) AND TPS, MYSURU, 1ST FLOOR, AYAKAR BHAVAN, REAC, MYSURU - 570 008 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39317 WP No. 4377 of 2025 BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560095 3. ASSESSMENT UNIT, 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 WP IS FILED PRAYING TO QUASHING THE UNSIGNED SANCTION ACCORDED UNDER SECTION 151 OF THE ACT DATED 23.02.2024 FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO.2 BEARING DIN ITBA/AST/S/118/2023-24/1061405808(1) HEREIN MARKED AS ANNEXURE A. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39317 WP No. 4377 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 unsigned sanction accorded under section 151 of the Act dated 23.02.2024 for the assessment year 2020-21 by the Respondent No.2 bearing DIN ITBA/AST/S/118/2023- 24/1061405808(1) herein marked as Annexure - A. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 01.03.2024 passed under section 148A(d) of the Act for the assessment year 2020-21 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/F/148A/2023- 24/1061809458(1) herein marked as Annexure - A1. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 01.03.2024 issued under section 148 of the Act for the assessment year 2020- 21 by the Respondent No.1 bearing DIN & No. Notice ITBA/AST/S/148_1/2023- 24/1061810759(1) herein marked as Annexure A2. d) 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:39317 WP No. 4377 of 2025 2. Heard Smt. Lochana S. Babu, 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, - 5 - HC-KAR NC: 2025:KHC:39317 WP No. 4377 of 2025 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.: 2 Sl No.: 70