- 1 - HC-KAR NC: 2025:KHC:37389 WP No. 10189 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 10189 OF 2024 (T-IT) BETWEEN: USHA SARAOGI AGED 59 YEARS, D/O MAHAVIR PRASAD AGGARWAL NO.4071, 30TH CROSS, BSK 2ND STAGE, BANGALORE- 560070. PAN. AAYPD5079N …PETITIONER (BY SRI. SUDHEENDRA B R.,ADVOCATE) AND: 1. INCOME TAX OFFICER WARD 7(2)(5), BANGALORE BMTC BUILDING, 4TH FLOOR, 80 FEET ROAD, KORAMANGALA, BANGALORE - 560 095. 2. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KARNATAKA AND GAO, CR BUILDING NO.1 QUEENS ROAD, BANGALORE - 560 001. 3. CENTRAL BOARD OF DIRECT TAXES, NORTH BLOCK, CENTRAL SECRETARIAT, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37389 WP No. 10189 of 2024 NEW DELHI DELHI - 110 001 REPRESENTED BY THE SECRETARY, TAX POLICY AND LEGISLATIVE DIVISION 4. NATIONAL FACELESS ASSESSMENT CENTRE, REP BY ADDITION/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. …RESPONDENTS (BY SRI. E.I.SANMATHI., ADVOCATE) THIS WP IS FILED UNDER ARTILCES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE ORDER UNDER SECTION 148A(d) NOTICE DTD 27.07.2022 PASSED BY THE R1 FOR THE ASSESSMENT YEAR 2013.14(ANNEXURE-F)., AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN B GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:37389 WP No. 10189 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “(A) Quashing the order under section 148A(d) dated 27.7.2022 passed by the Respondent No. 1 for the assessment year 2013-14 (Annexure F) (B) Quashing the manual notice dated 27.07.2022 issued by the Respondent No. 1 under Section 148 of the Act for the assessment year 2013-14 without DIN (Annexure G) (C) Quashing the assessment order passed by the Respondent No. 4 under Section 147 rws 144B of the Act dated 26.05.2023 bearing DIN and Notice No ITBA/AST/S/147/2023-24/1053229134(1) for the AY 2013-14 (Annexure J) (D) Quashing the Computation sheet issued by the Respondent No. 4 dated 26.05.2023 bearing DIN and Document No. ITBA/AST/S/114/2023- 24/1053229169(1) for the AY 2013-14 (Annexure K) (E) Quashing the Notice of demand under section 156 issued by the Respondent No. 4 dated 26.05.2023 bearing DIN and Notice No. ITBA/AST/S/156/2023-24/1053229160(1) for (Annexure L) the AY 2013-14 (F) Quashing the Penalty notice dated 26.05.2023 issued u/s 274 rws 271(1)(c) bearing DIN and Notice No. ITBA/PNL/S/271(1)(c)/2023- 24/1053229183(1) for the AY 2013-14 (Annexure M) (G) Quashing the Penalty order dated 01.03.2024 Issued u/s 274 rws 271(1)(b) bearing DIN and Notice No. ITBA/PNL/F/271(1)(b)/2023- - 4 - HC-KAR NC: 2025:KHC:37389 WP No. 10189 of 2024 24/1061844820(1) for the AY 2013-14 (Annexure P) (H) Quashing the instruction bearing No. 1/2022 (F. No. 279/Misc/M-51/2022-ITJ) dated 11.05.2022 issued by the 3rd Respondent (Annexure Q), to the extent questioned herein; And (I) Passing such other or further orders as this Honourable High Court may think fit in the facts and circumstances of the case, in the interests of justice and equity." 2. Heard Shri Sudheendra B.R., learned counsel appearing for the petitioner and Shri E.I. Sanmathi, 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: - 5 - HC-KAR NC: 2025:KHC:37389 WP No. 10189 of 2024 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, 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.: 1 Sl No.: 58