- 1 - HC-KAR NC: 2025:KHC:37380 WP No. 13013 of 2023 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. 13013 OF 2023 (T-IT) BETWEEN: RAGHAVENDRA PRASAD T S AGED 47 YEARS, S/O T R SUBRAMANIAN, NO 43, MANGALA BRINDAVANA, SRI VENKATESHWARA KRUPA LAYOUT, BASAVESHWARAR NAGAR, BANGALORE 560 079 PAN AEUPP6152J …PETITIONER (BY SRI. SUDHEENDRA B R., ADVOCATE) AND: 1. ASSISTANT/DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 6(1)(1), BANGALORE, BMTC BUILDING, 6TH BLOCK, KORAMANGALA, BANGALORE 560 095 2. PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU - 1 BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILAGE, KORAMANGALA, BENGALURU 560095 REPRESENTING THE NATIONAL FACELESS ASSESSMENT CENTRE 3. CENTRAL BOARD OF DIRECT TAXES Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37380 WP No. 13013 of 2023 DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, NORTH BLOCK NEW DELHI 110002 REPRESENTED HEREIN BY ITS CHAIRPERSON 4. NATIONAL FACELESS ASSESSMENT CENTRE REP BY 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 …RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE FOR R1 TO R4) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO-QUASH THE ORDER U/S 148A(d) DTD 29/07/2022 PASSED BY THE ACIT/DCIT CIRCLE 6(1)(1), BANGALORE I.E., R-1 WITH DIN AND ORDER NO. ITBA/COM/F/17/2022-23/1044302940(1) FOR THE AY 2016-17 (ANNEXURE-F4)., 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:37380 WP No. 13013 of 2023 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayer: “(A) Quashing the Order under section 148A(d) dated 29.7.2022 passed by the ACIT/DCIT, Circle 6(1) (1), Bangalore i.e., respondent no 1 with DIN & Order No ITBA/COM/F/17/2022- 23/1044302941(1) for the AY 2016-17 (Annexure F4) (B) Quashing the Notice under section 148 dated 29.7.2022 issued by ACIT, Circle 6(1)(1), Bangalore i.e., respondent no 1 for the AY 2016- 17 (Annexure G1) (C) Quashing the Assessment order under section 147 rws 1448 passed by the Assessment Unit, National Faceless Assessment Centre l.e., respondent no 4 dated 18.5.2023 with DIN ITBA/AST/S/147/2023- 24/1052971836(1) for the AY 2016-17 (Annexure P1) (D) Quashing the Computation sheet passed by the Assessment Unit, National Faceless Assessment Centre i.e., respondent no 4 dated 18.5.2023 with DIN & Document No ITBA/AST/S/114/2023- 24/1052972052(1) for the AY 2016-17 (Annexure P2) (E) Quashing the Notice of demand under section 156 passed by the Assessment Unit National Faceless Assessment Centre i.e., respondent no 4 dated 18.5.2023 with DIN & Notice No ITBA/AST/S/156/2023-24/1052971942(1) for the AY 2016-17 (Annexure P3) (F) Quashing the Notice for Penalty under section 274 read with section 271(1)(c) issued by the - 4 - HC-KAR NC: 2025:KHC:37380 WP No. 13013 of 2023 Assessment unit National Faceless Assessment Centre i.e., respondent no 4 dated 18.5.2023 with DIN ITBA/PNL/S/271(1)(c)/2023- 24/1052996708(1) for the AY 2016-17 (Annexure P4) (G) Quashing the Instruction bearing No.1/2022 dated 11.05.2022 Issued by the Respondent No. 3 (Annexure-Q) to the extent challenged in this writ petition (H) 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 respondents No.1 to 4. 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: ORDER - 5 - HC-KAR NC: 2025:KHC:37380 WP No. 13013 of 2023 (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.: 55