- 1 - HC-KAR NC: 2025:KHC:39712 WP No. 14669 of 2024 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. 14669 OF 2024 (T-IT) BETWEEN: JAGANNATH MANJUNATHA AGED ABOUT 38 YEARS S/O LATE R.JAGANATH NO.201-2, AVANI TALUK: MULABAGILU KOLAR - 563 131. …PETITIONER (BY SRI RAVI SHANKAR S. V., ADVOCATE) AND: 1. INCOME TAX OFFICER WARD - 1(2)(1) BENGALURU - 560 095. 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. 3. THE PRINCIPAL COMMISSIONER Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39712 WP No. 14669 of 2024 OF INCOME TAX - 1 THE OFFICE OF THE PRINCIPAL COMMISSIONER OF INCOME TAX BMTC BUILDING, BENGALURU – 560 095. …RESPONDENTS (BY SRI M.DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO DIRECT, QUASH THE NOTICE UNDER SECTION 148A(b) OF THE ACT, DTD 24.03.2022 BEARING DIN NO. ITBA/AST/F/148A(SCN)/2021- 22/1041441667(1), ISSUED BY THE R-1 FOR THE ASSESSMENT YEAR 2018-19 HEREIN MARKED AS ANNEXURE- A; DIRECT, QUASHING THE ORDER UNDER SECTION 148A(d) OF THE ACT, DTD 01.04.2022, BEARING DIN NO. ITBA/AST/F/148A/2022-23/1042419947(1) ISSUED BY THE R-1 FOR THE AY 2018-19 HEREIN MARKED AS ANNEXURE-A1; DIRECT, QUASHING THE NOTICE UNDER SEC 148 OF THE ACT DTD 01.04.2022 BEARING DIN NO. ITBA/AST/S/148-1/2022- 23/1042420730(1) ISSUED BY THE R-1 FOR THE AY 2018-19 HEREIN MARKED AS ANNEXURE-A2; DIRECT, QUASHING THE ORDER PASSED U/S 147 R.W.S 144, 144B DTD 16.11.2023 BEARING DIN NO. ITBA/AST/S/147/2023-24/1058009500(1) ISSUED BY THE R-2 FOR THE AY 2018-19 HEREIN MARKED AS ANNEXURE-A3; DIRECT, QUASHING THE PENALTY ORDER UNDER SEC 270A OF THE ACT DTD 21.05.2024 BEARING DIN NO. ITBA/PNL/F/270A/2024-25/1065088832(1), ISSUED BY THE R-2 FOR THE AY 2018-19 HEREIN MARKED AS ANNEXURE- A4; DIRECT, QUASHING THE PENALTY ORDER UNDER SEC 271AAC(1) OF THE ACT DTD 22.05.2024 BEARING DIN NO. ITBA/PNL/F/271AAC(1)/2024-25/1065085517(1) ISSUED BY THE R-2 FOR THE AY 2018-19 HEREIN MARKED AS ANNEXURE- A5; DIRECT, QUASHING THE PENALTY ORDER UNDER SEC 272A(1)(d) OF THE ACT DTD 21.05.2024 BEARING DIN NO. ITBA/PNL/F/272A(1)(d)_FL/2024-25/1065025992(1) ISSUED BY THE R-2 FOR THE AY 2018-19 HEREIN MARKED AS ANNEXURE-A6. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39712 WP No. 14669 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/AST/F/148A(SCN)/2021-22/1041441667(1) dated 24.03.2022, ITBA/AST/S/148_1/2022-23/1042420730(1) dated 01.04.2022 and order Nos.ITBA/AST/F/148A/2022- 23/1042419947(1) dated 01.04.2022, ITBA/AST/S/147/2023- 24/1058009500(1) dated 16.11.2023, ITBA/PNL/F/270A/2024- 25/1065088832(1) dated 21.05.2024, ITBA/PNL/F/271AAC(1)/2024-25/1065085517(1) dated 22.05.2024, ITBA/PNL/F/272A(1)(d)_FL/2024- 25/1065025992(1) dated 21.05.2024 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Ravishankar S.V., learned counsel for the petitioner and Sri M. Dilip, learned counsel for the respondents. 3. The grounds projected in the subject petition in support of the prayer quoted supra are identical to the ones - 4 - HC-KAR NC: 2025:KHC:39712 WP No. 14669 of 2024 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 notices bearing No. ITBA/AST/F/148A(SCN)/2021-22/1041441667(1) dated 24.03.2022 and ITBA/AST/S/148_1/2022- 23/1042420730(1) dated 01.04.2022 issued by the jurisdictional Assessing Officer outside the scope of Section 151A 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 - 5 - HC-KAR NC: 2025:KHC:39712 WP No. 14669 of 2024 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 2 Sl No.: 35 CT:SS