- 1 - HC-KAR NC: 2025:KHC:52409 WP No. 36095 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 10TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 36095 OF 2025 (T-IT) BETWEEN: M/S. POLKI S NO.54/18, 1ST FLOOR, 8TH F MAIN ROAD, 3RD BLOCK, JAYANAGARA, BENGALURU - 560 011, REP. BY ITS PARTNER SMT. PRAMILA LODHA, W/O SRI KISHORE KUMAR LODHA, AGED ABOUT 60 years ALSO AT NO.4, 4TH FLOOR, 24TH CROSS, 6TH BLOCK, YADIYUR LAKE, JAYANAGAR, VTC: BANGALORE SOUTH PO: UDAYPURA, SUB DIST: BANGALORE SOUTH, BENGALURU - 560 082 REP. BY ITS GENERAL POWER OF ATTORNEY (GPA) SRI MANISH LODHA, S/O SRI KISHORE KUMAR, AGED ABOUT 39 YEARS …PETITIONER (BY SRI. ABHIJITH S. BAPU, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1(2), BENGALURU, CENTRAL REVENUE BUILDING, Digitally signed by SHARADAVANI B Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:52409 WP No. 36095 of 2025 QUEENS ROAD, BENGALURU - 560 001 EMAIL: BANGALORE.DCIT.CEN1.2@INCOMETAX.GOV.IN 2. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), BENGALURU THE SPECIFIED AUTHORITY UNDER SECTION 151 OF THE INCOME TAX ACT, 1961 CENTRAL REVENUE BUILDING, QUEENS RAOD, BANGALORE - 560 001 3. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), A CENTRE DESCRIBED 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) 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. UNION OF INDIA REPRESENTED BY THE DIRECTOR, DEPARTMENT OF REVENUE MINISTRY OF FINANCE, ROOM NO 46, NORTH BLOCK, NEW DELHI - 110 001. …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) - 3 - HC-KAR NC: 2025:KHC:52409 WP No. 36095 of 2025 THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A. ISSUE A WRIT OF CERTIORARI OR ANY OTHER SUITABLE WRIT FOR QUASHING OF THE ELECTRONICALLY COMMUNICATED APPROVAL U/S 151 OF THE INCOME TAX ACT, 1961, DATED 24/09/2024 ISSUED BY THE RESPONDENT NO. 2 FOR THE ASSESSMENT YEAR 2021-22 WHICH BEARS THE DIN NO. ITBA/AST/S/125/2024-25/1069016748(1) AND ENCLOSED AS ANNEXURE C AND ETC., THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER 1. In this petition, the petitioner seeks the following reliefs: a. Issue a writ of certiorari or any other suitable writ for quashing of the electronically communicated Approval u/s 151 of the Income Tax Act, 1961, dated 24/09/2024 issued by the Respondent No. 2 for the Assessment Year 2021-22 which bears the DIN No. ITBA/AST/S/125/2024-25/1069016748(1) and enclosed as Annexure C. b. 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 03/10/2024 issued by the Respondent No. 1 for the Assessment Year 2021-22 which bears the DIN &Notice No. ITBA/AST/S/1481/2024- 25/1069359023(1) and enclosed as Annexure D. c. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice u/s 143(2) of the Income Tax Act, 1961 dated 1612/202 issued by the Respondent - 4 - HC-KAR NC: 2025:KHC:52409 WP No. 36095 of 2025 No. 1 for the Assessment Year 2021-22 which bears the DIN No. ITBA/AST/F/143(2)_4/2024- 25/1071075960(1) and enclosed as Annexure E. d. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated Assessment Order u/s 147 of the Income Tax Act, 1961 dated 27/03/2025 issued by the Respondent No. 1 for the Assessment Year 2021- 22 which bears the DIN & Order No. ITBA/AST/S/147/2024-25/1075107998(1)) and enclosed as Annexure F1. e. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated Notice of demand u/s 156 of the IncomeTax Act, 1961 dated 27/03/2025 issued by the Respondent No. 1 for the Assessment Year 2021- 22 which bears the DIN & Notice No. ITBA/AST/S/156/2024-25/1075108138(1) and enclosed as Annexure F2. f. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated Computation Sheet dated 27/03/2025 issued by the Respondent No. 1 for the Assessment Year 2021-22 which bears the DIN & Document No. ITBA/AST/S/521/2024-25/1075108114(1) and enclosed as Annexure F3. g. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated show cause notice u/s 270A of the Income Tax Act, 1961, dated 27/03/2025 issued by the Respondent No. 1 for the Assessment Year 2021- 22 which DIN the bears ITBA/PNL/S/270A/2024-No. 25/1075108076(1) and enclosed as Annexure G. h. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated Order u/s 270A of the Income Tax - 5 - HC-KAR NC: 2025:KHC:52409 WP No. 36095 of 2025 Act, 1961, dated 26/09/2025 issued by the Respondent No. 1 for the Assessment Year 2021-22 which bears the DIN No. ITBA/PNL/F/270A/2025- 26/1081273420(1) and enclosed as Annexure J1. i. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated Notice of demand u/s 156 of the Income Tax Act, 1961, dated 26/09/2025 issued by the Respondent No. 1 for the Assessment Year 2021- 22 which bears the DIN No. ITBA/PNL/S/156/2025- 26/1081273415(1) and enclosed as Annexure J2. j. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated Computation Sheet, dated 26/09/2025 issued by the Respondent No. 1 for the Assessment Year 2021-22 which bears the DIN No. ITBA/PNL/S/992/2025-26/1081239191(1) and enclosed as Annexure J3. 2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitioner invited my attention to the order of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - - 6 - HC-KAR NC: 2025:KHC:52409 WP No. 36095 of 2025 W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order. 4. Per contra, learned counsel for the respondents submits that there is no merit in the petition and that the same is liable to be dismissed. 5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under: "13. I, therefore, pass the following: O R D E R (i) The impugned show cause notices issued by the jurisdictional Assessing Officer outside the scope of Section 151-A of the Act stand - 7 - HC-KAR NC: 2025:KHC:52409 WP No. 36095 of 2025 obliterated. All further proceedings initiated thereto, challenged in these cases would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of these petitions would become necessary." 6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of co-ordinate Bench of this Court in Ramachandra Reddy's case supra. 7. In the result, I pass the following: ORDER (i) The petition is allowed and disposed of in terms of the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - - 8 - HC-KAR NC: 2025:KHC:52409 WP No. 36095 of 2025 W.P.No.17352/2022 and connected matters - dated 28.08.2025. (ii)The impugned show cause notices and consequential orders, notices etc., at Annexures-C, D, E, F1, F2, F3, G, J1, J2, J3 and L dated 24.09.2024, 03.10.2024, 10.12.2024, 27.03.2025, 27.03.2025, 27.03.2025, 27.03.2025, 26.09.2025, 26.09.2025 and 26.09.2025 respectively are hereby quashed. (iii) Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, subsequent to disposal of the matters pending before the Apex Court and all rival contentions between the parties in this regard are kept open and no opinion is expressed on the same. Sd/- (S.R.KRISHNA KUMAR) JUDGE GH List No.: 2 Sl No.: 42