- 1 - HC-KAR NC: 2025:KHC:35437 WP No. 23497 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. 23497 OF 2024 (T-IT) BETWEEN: 1. RAKSHITH JAGANNATH PERIKAL S/O P M JAGANNATH AGED ABOUT 34 YEARS No. 1875, 31ST CROSS 9TH MAIN ROAD, 2ND STAGE, BANASHANKARI BANGALORE - 560 070. …PETITIONER (BY SRI. RAMA MURTHY R, ADVOCATE) AND: 1. ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTER DELHI - 110 001. 2. THE INCOME TAX OFFICER WARD 7(2)(5), KORAMANGALA BANGALORE - 560 095. …RESPONDENTS (BY SRI ARAVIND V CHAVAN, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:35437 WP No. 23497 of 2024 THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ORDER OF ASSESSMENT DATED 30/07/2024 IN DIN ITBA/AST/S/147/2024-25/1067126391(1) MADE U/S 147 R.W. 144B OF THE ACT (ANNX-H) TO THIS WP AND DIRECT THE RESPONDENT TO ISSUE SUMMONS U/S 131 OF THE ACT TO M/S ABHUDAYA DEVELOPERS PRIVATE LTD. WHOSE ADDRESS AND DETAILS, THE PETITIONER HAS FURNISHED TO THE RESPONDENT, AS THE COMPANY HAS NOT RESPONDED TO THE NOTICE ISSUED U/S 133(6) OF THE ACT, THOUGH THE COMPANY IS BOUND TO RESPOND TO THE STATUTORY NOTICE AND DIRECT THE RESPONDENT SUCH STEPS SEEKING COMPLIANCE FROM M/S ABHUDAYA DEVELOPERS PRIVATE LTD.C) DIRECT THE RESPONDENT TO CONSIDER THE CONFIRMATION NOW PROVIDED BY MR. MALLIKARJUNAIAH CONFIRMING RETURN OF THE ADVANCE TAKEN FOR SITE, WHICH THE PETITIONER COULD PRODUCE BEFORE THE RESPONDENT AND ETC., THIS PETITION, COMING ON FOR ORDERS THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notice bearing No.ITBA/PNL/S/271AAC(1)/2024- 25/1067126524(1) dated 30.07.2024 and an order of - 3 - HC-KAR NC: 2025:KHC:35437 WP No. 23497 of 2024 assessment No.ITBA/AST/S/147/2024-25/1067126391(1) dated 30.07.2024 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Rama Murthy R., learned counsel for the petitioner and Sri Aravind V. Chavan, 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: ORDER (i) The impugned notice bearing No. ITBA/PNL/S/271AAC(1)/2024-25/1067126524(1) dated 30.07.2024 issued by the jurisdictional Assessing Officer outside the scope of Section 151A - 4 - HC-KAR NC: 2025:KHC:35437 WP No. 23497 of 2024 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.: 393