- 1 - HC-KAR NC: 2025:KHC:46504 WP No. 33593 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 10TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 33593 OF 2025 (T-IT) BETWEEN: NANJAPPAN VEDIYAPPAN AGED ABOUT 40 YEAR, SON OF SRI. NANJAPPAN, PRESENTLY AT NO. 54, 2ND CROSS, KRISHNA REDDY LAYOUT, HBR 3RD BLOCK, KALYAN NAGAR, BENGALURU – 560 043 PREVIOUSLY AT, NO.207, HENNUR SERVICE ROAD, BESIDE MASJID, KACHARKANAHALLI, BENGALURU – 560 043 …PETITIONER (BY SRI. SHREEHARI KUTSA,ADVOCATE) AND: 1. INCOME TAX OFFICER ITO WARD 2(1)(1), BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095. EMAIL.BANGALORE.ITO2.1.1@INCOMETAX.GOV.IN 2. CHIEF COMMISSIONER OF INCOME TAX BENGALURU-1, THE SPECIFIED AUTHORITY UNDER SECTION 151 OF THE INCOME TAX ACT, 1961 BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALORE – 560 095 Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:46504 WP No. 33593 of 2025 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. PRINCIPAL COMMISSIONER OF INCOME TAX-1, BENGALURU BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALORE – 560 095 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS W.P. 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 09/08/2024 ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2018-19 WHICH BEARS THE DIN AND NOTICE NO.ITBA/AST/F/148A(SCN)/2024-25/1067508805(1) AND ENCLOSED AS ANNEXURE-A 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 - 3 - HC-KAR NC: 2025:KHC:46504 WP No. 33593 of 2025 ORAL ORDER In this petition, petitioner seeks for the following reliefs:- “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 09/08/2024 issued by the Respondent No. 1 for the Assessment Year 2018-19 which bears the DIN & Notice No. ITBA/AST/F/148A(SCN)/2024-25/1067508805(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 30/08/2024 issued by the Respondent No. 1 for the Assessment Year 2018-19 which bears the DIN & Notice No. ITBA/AST/F/148A/2024-25/1068149654(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 148 of the Income Tax Act, 1961 dated 30/08/2024 issued by the Respondent No.1 for the Assessment Year 2018-19 which bears the DIN & Notice No. ITBA/AST/S/148_1/2024- 25/1068151865(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 - 4 - HC-KAR NC: 2025:KHC:46504 WP No. 33593 of 2025 communicated assessment order u/s 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act, 1961 dated 17/10/2025 issued by the Respondent No. 4 for the Assessment Year 2018-19 which bears the DIN & Notice No. ITBA/AST/S/147/2025-26/1081873606(1) and enclosed as Annexure N1. 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 Income Tax Act, 1961 dated 17/10/2025 issued by the Respondent No. 4 for the Assessment Year 2018-19 which bears the DIN & Notice No. ITBA/AST/S/156/2025-26/1081875641(1) and enclosed as Annexure N2. f. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated Computation Sheet dated 17/10/2025 issued by the Respondent No. 4 for the Assessment Year 2018-19 which bears the DIN & Notice No. ITBA/AST/S/183/2025-26/1081875371(1) and enclosed as Annexure N3. g. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice for penalty u/s 274 r.w.s. 270A of the Income Tax Act, 1961 dated 17/10/2025 issued by the Respondent No. 4 for the Assessment Year 2018-19 which bears the DIN No. - 5 - HC-KAR NC: 2025:KHC:46504 WP No. 33593 of 2025 ITBA/PNL/S/270A/2025-26/1081874976(1) and enclosed as Annexure P1. h. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice for penalty u/s 274 r.w.s. 272A(1)(d) of the Income Tax Act, 1961 dated 17/10/2025 issued by the Respondent No. 4 for the Assessment Year 2018-19 which bears the DIN No. ITBA/PNL/S/272A(1)(d)/2025-26/1081862572(1) and enclosed as Annexure P2. i. 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 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 - 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. - 6 - HC-KAR NC: 2025:KHC:46504 WP No. 33593 of 2025 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 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. - 7 - HC-KAR NC: 2025:KHC:46504 WP No. 33593 of 2025 (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 - 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-A, D, E, N1, N2, N3, P1 and P2 dated 09.08.2024, - 8 - HC-KAR NC: 2025:KHC:46504 WP No. 33593 of 2025 30.08.2024, 30.08.2024, 17.10.2025, 17.10.2025, 17.10.2025, 17.10.2025 and 17.10.2025 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 BMC List No.: 2 Sl No.: 45