- 1 - HC-KAR NC: 2025:KHC:39198 WP No. 6120 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. 6120 OF 2024 (T-IT) BETWEEN: SHIVARAMA REDDY ADINARAYANAREDDY, SON OF LATE SHRI SRINIVAS, AGED ABOUT 54 YEARS, NO 1, PAVAGADA, TUMAKURU 561202. …PETITIONER (BY SRI. RAVI SHANKAR S V, ADVOCATE) AND: 1. THE INCOME TAX OFFICER, WARD 1 AND TPS, TUMAKURU, AAYAKAR BHAVAN, RAMAKRISHNA NAGAR, KUNIGAL ROAD, TUMAKURU 572103. 2. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA AND GOA, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39198 WP No. 6120 of 2024 KORAMANGALA, BENGALURU 560095. 3. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E RAMP, JAWARLAL NEHRU STADIUM, DELHI 110003. …RESPONDENTS (BY SRI.M.DILIP, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE ISSUED UNDER SEC 148A(b) OF THE ACT DTD 17.03.2022 OF THE ACT OF THE ASSESSMENT YEAR 2015-16 BY THE RRESPONDENT NO.1 BEARING DIN AND NOTICE NO.ITBA/AST/F/148A(SCN)/2021-22/1040976097(1) HEREIN MARKED AS ANNEXURE-A AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39198 WP No. 6120 of 2024 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 notice issued under section 148A(b) of the Act dated 17.03.2022 of the Act for the assessment year 2015-16 by the Respondent No.1 bearing DIN & Notice No.ITBA/AST/F/148A(SCN)/2021-22/1040976097(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 28.03.2022 passed under section 148A(d) of the Act for the assessment year 2015-16 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/F/148A/2021- 22/1041790683(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 31.03.2022 issued under section 148 of the Act for the assessment year 2015-16 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/148_1/2021- 22/1042290442(1) herein marked as Annexure - A2. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 18.03.2023 passed under section 147 of the Act for the assessment year 2015-16 by the Respondent No.3 bearing DIN & Notice No. ITBA/AST/S/147/2022-23/1050920196(1) herein marked as Annexure - A3. e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 11.09.2023 passed under section 271(1)(c) of the Act for the assessment year 2015-16 by the Respondent - 4 - HC-KAR NC: 2025:KHC:39198 WP No. 6120 of 2024 No.3 bearing DIN & Notice No.ITBA/PNL/F/271(1)(c)/2023-24/1055924520(1) herein marked as Annexure - A4. f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 30.08.2023 passed under section 271(1)(b) of the Act for the assessment year 2015-16 by the Respondent No.3 bearing DIN & Notice No. ITBA/PNL/F/271(1)(b)/2023-24/1055627393(1) herein marked as Annexure - A5. g) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri.Ravi Shankar 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 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: - 5 - HC-KAR NC: 2025:KHC:39198 WP No. 6120 of 2024 ORDER (i) The impugned show cause notice 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 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE CBC List No.: 2 Sl No.: 11