- 1 - HC-KAR NC: 2025:KHC:37898 WP No. 33406 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28TH DAY OF AUGUST, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO.33406 OF 2024 (T-IT) BETWEEN: BANGARU JAYA SHEKAR SON OF SRI. BANGARU, AGED ABOUT 55 YEARS NO.6, SHANTHA NILAY, 2ND MAIN ROAD, VIDYARANYAPURAM, MYSURU – 570 008 …PETITIONER (BY SRI. SHREEHARI., ADVOCATE) AND: 1. INCOME TAX OFFICER WARD 1(1) MYSURU REAC, MYSURU REAC, MYSURU – 570 008 EMAIL MYSORE.ITO1.1@INCOMETAX.GOV.IN 2. PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU-3, THE SPECIFIED AUTHORITY UNDER SECTION 151 OF THE INCOME TAX ACT, 1961 BMTC BUILDING, BMTC BHAVAN, 80 FEET ROAD, (NEAR SONY WORLD SIGNAL) KORAMANGALA, BENGALURU – 560 034 3. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), A CENTRE DESCRIBED UNDER SECTION 144B Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37898 WP No. 33406 of 2024 OF THE INCOME TAX ACT, 1961 ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 REP. BY PR. CHIEF COMMISSIONER INCOME TAX (NEAC) 4. ASSESSMENT UNIT A UNIT CREATED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961 ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC) 5. ASSISTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, CIRCLE 1(2), BENGALURU AUTHORITY CLAIMING TO BE THE JURISDICTIONAL ASSESSING OFFICER BMTC BUILDING, 80FT ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095 …RESPONDENTS (BY SRI. E. I. SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR ANY OTHER SUITABLE WRIT FOR QUASHING OF THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED NOTICE U/S 148A(b) OF THE INCOME TAX ACT, 1961 DATED 30/03/2022 ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2018-19 WHICH BEARS THE DIN VIZ., ITBA/AST/F/148A(SCN)/2021-22/1042116623(1) AND ENCLOSED AS ANNEXURE A 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:37898 WP No. 33406 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayer: “a. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice u/s 148A(b) of the Income Tax Act, 1961 dated 30/03/2022 issued by the Respondent No. 1 for the Assessment Year 2018-19 which bears the DIN ITBA/AST/F/148A(SCN)/2021-viz., 22/1042116623(1) and enclosed as Annexure A. b. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated order u/s 148A(d) of the Income Tax Act, 1961 dated 30/04/2022 issued by the Respondent No. 1 for the Assessment Year 2018-19 which bears the DIN viz., ITBA/AST/F/148A/2022-23/1042919766(1) and enclosed as Annexure B. c. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice u/s 148 of the Income Tax Act, 1961 dated 30/04/2022 issued by the Respondent No. 1 for the Assessment Year 2018-19 which bears the DIN viz., ITBA/AST/S/148_1/2022-23/1042919981(1) enclosed as Annexure C. and d. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice under section 143(2) r.w.s. 147 of the Income-tax Act, 1961 dated 17/03/2024 issued by the Respondent No. 5 for the Assessment Year 2018-19 which bears the - 4 - HC-KAR NC: 2025:KHC:37898 WP No. 33406 of 2024 DIN viz., ITBS/AST/F/143(2)_4/2023- 24/1062795009(1) and enclosed as Annexure L. e. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated draft order under section 144C(1) of the Income-tax Act, 1961, dated 19/03/2024 issued by the Respondent No. 5 for the Assessment Year 2018-19 which bears the DIN viz., ITBA/AST/F/144C/2023- 24/1062895682(1) and enclosed as Annexure M. f. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated assessment order under section 147 r.w.s 144C(3) of the Income Tax Act, 1961 dated 29/05/2024 passed by the Respondent No. 5 for the Assessment Year 2018-19 which bears the DIN viz., ITBA/AST/S/147/2024- 25/1065228105(1) and enclosed as Annexure P1. g. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice of demand under section 156 of the Income Tax Act, 1961 dated 29/05/2024 issued by the Respondent No. 5 for the Assessment Year 2018-19 ITBA/AST/S/156/2024-which bears the DIN viz. 25/1065228244(1) and enclosed as Annexure P2. h. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated computation sheet dated 29/05/2024 issued by the Respondent No. 5 for the Assessment Year bears which 2018-19 DIN the viz., ITBS/AST/S/183/2024-25/1065228232(1) and enclosed as Annexure P3. i. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice under section 274 r.w.s. 270A of the Income-tax Act, 1961 dated 29/05/2024 issued by the Respondent No. 5 for the Assessment Year 2018-19 which bears the DIN viz., - 5 - HC-KAR NC: 2025:KHC:37898 WP No. 33406 of 2024 ITBA/PNL/F/270A/2024-25/1065228187(1) and enclosed as Annexure Q. j. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice under section 274 r.w.s. dated 271AAC(1) of the Income-tax Act, 1961 31/05/2024 issued by the Respondent No. 5 for the Assessment Year 2018-19 which bears the DIN viz., ITBA/PNL/F/271AAC(1)/2024- 25/1065320796 (1) and enclosed as Annexure R. k. Grant such other reliefs as this Hon'ble Court deems fit in this matter including but not limited to COST OF THIS PETITION.” 2. Heard Sri Shreehari, learned counsel for the petitioner and Sri E.I.Sanmathi, 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: - 6 - HC-KAR NC: 2025:KHC:37898 WP No. 33406 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 NVJ List No.: 1 Sl No.: 407