- 1 - HC-KAR NC: 2025:KHC:40924 WP No. 30865 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 15TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 30865 OF 2025 (T-IT) BETWEEN: KUMAR RAJU AMPALLI NARAYANA RAJU, AGED ABOUT 68 YEARS, S/O AMPALLI NARAYANA RAJU, NO.164, 20TH MAIN, 14TH CROSS, II PHASE, JP NAGAR, BENGALURU - 560 078. …PETITIONER (BY SRI MADHUSUDHAN U A, ADVOCATE) AND: 1. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE, MINISTRY OF FINANCE, ROOM NO 401, 2ND FLOOR, E-RAMP, JAWARLAL NEHRU STADIUM, DELHI-110 003. 2. THE INCOME TAX OFFICER, WARD-4(3)(3), BMTC BUILDING, 80FT ROAD, 6TH BLOCK, KHB VILLAGE, KORAMANGALA BENGALURU - 560095. 3. THE CHIEF COMMISSIONER OF INCOME TAX-1, CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560001. …RESPONDENTS (BY SRI E.I SANMATHI, ADVOCATE FOR R-1 TO R-3) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A) QUASH THE ASSESSMENT ORDER DATED 06.01.2025 PASSED UNDER SECTION 147 R.W.S 144 R.W.S 144B OF THE INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2017-18 BY THE RESPONDENT NO.1 BEARING DIN NO. ITBA/AST/S/147/2024-25/1072378158(1) HEREIN MARKED AS ANNEXURE - A1. ETC. Digitally signed by NANDINI R Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:40924 WP No. 30865 of 2025 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 1. In this petition, the petitioner seeks the following reliefs: "Wherefore it is prayed that this Hon'ble Court be pleased to: a). Issue a writ of certiorari or direction in the nature of a writ of certiorari quashing the assessment order dated 06.01.2025 passed under section 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent No.1 bearing DIN No. ITBA/AST/S/147/2024- 25/1072378158(1) herein marked as Annexure-A1. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 06.01.2025 for the Assessment Year 2017-18 issued by the Respondent No.1 bearing DIN & Document No. ITBA/AST/S/213/2024- 25/1072378721(1) herein marked as Annexure-A2. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand dated 06.01.2025 issued under section 156 of the Income Tax Act, 1961, for the Assessment Year 2017-18 issued by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/156/2024- 25/1072387868(1) herein marked as Annexure-A3. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 21.07.2025 passed - 3 - HC-KAR NC: 2025:KHC:40924 WP No. 30865 of 2025 under section 271AA(1) of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent No.1 bearing DIN No. ITBA/PNL/F/271AAC(1)/2025-26/1078728841(1) herein marked as Annexure-A4. e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 21.07.2025 issued pertaining to penalty under section 271AAC(1) of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent No.1 bearing DIN & Order No. ITBA/PNL/F/271AAC(1)/2024-25/1072378453(1) herein marked as Annexure-A5. f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the demand notice dated 21.07.2025 issued Notice to Demand under section 156 of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent No.1 bearing DIN & Notice No. ITBA/PNL/S/156/2025- 26/1078728764(1) herein marked as Annexure-A6. g) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 16.07.2025 passed under Section 272A(1)(d) of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent No.1 bearing DIN No. ITBA/PNL/F/272A(1)(d)/2025-26/1078576298(1) herein marked as Annexure-A7. h) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 16.07.2025 issued pertaining to penalty under section 272A(1)(d) of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent No.1 bearing DIN & Order No. - 4 - HC-KAR NC: 2025:KHC:40924 WP No. 30865 of 2025 ITBA/PNL/S/272A(1)(d)_FL/2024-25/107852049(1) herein marked as Annexure-A8. i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the demand notice dated 16.07.2025 issued notice to Demand under Section 156 of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent No.1 bearing DIN & Notice No. ITBA/PNL/S/156/2025- 26/1078576185(1) herein marked as Annexure-A9. j) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 02.03.2024 issued section 148(a) of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent No.2 bearing DIN & Letter No. ITBA/AST/F/17/2023-24/1061876630(1) herein marked as Annexure-B1. k) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 12.03.2024 issued section 148A(b) of the Income Tax Act, 1961 for the assessment year 2017-18 Respondent No.2 bearing DIN & Notice No. ITBA/AST/F/148A(SCN)/2023-24/1062496094(1) herein marked as Annexure-B2. l) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 22.03.2024 passed under 148A(d) of the Income Tax Act, 1961 for the assessment year 2017-18 by the Respondent No.2 bearing DIN & Notice No. ITBA/AST/F/148A/2023-24/1063212055(1) herein marked as Annexure-B3. m) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 28.03.2024 issued under - 5 - HC-KAR NC: 2025:KHC:40924 WP No. 30865 of 2025 section 148 of the Income Tax Act, 1961 for the assessment year 2017-18 by the Respondent No.2 bearing DIN & Notice No. ITBA/AST/S/148_1/2023-24/1063548148(1) herein marked as Annexure-B4. n) And pass such other orders as this Hon'ble Court deems fit and proper 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. 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 - 6 - HC-KAR NC: 2025:KHC:40924 WP No. 30865 of 2025 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. (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 - 7 - HC-KAR NC: 2025:KHC:40924 WP No. 30865 of 2025 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-A1 to 3 dated 06.01.2025; Annexures A4 to 6 dated 21.07.2025; Annexures A7 to 9 dated 16.07.2025; Annexure- B1 dated 02.03.2024; Annexure-B2 dated 12.03.2024; Annexure-B3 dated 22.03.2024 and Annexure-B4 dated 28.03.2024 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 tsn*/List No.: 2 Sl No.: 38