- 1 - HC-KAR NC: 2025:KHC:38246 WP No. 23938 of 2025 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.23938 OF 2025 (T-IT) BETWEEN: SRI. PRASAD BANASWADI SATYANARAYANAREDDY, S/O LATE SRI. B. M. SATHYANARAYANA REDDY, AGED ABOUT 45 YEARS, 141/1, 1ST MAIN, HORAMAVU MAIN ROAD, BANGALORE NORTH, BENGALURU - 560 043. …PETITIONER (BY SRI. JOSEPH VARGHESE, ADVOCATE) AND: 1. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, REP. BY ADDL/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. 2. THE INCOME TAX OFFICER, WARD-1(2)(1), BANGALORE, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:38246 WP No. 23938 of 2025 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-1, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 4. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BLR, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF WRIT OF CERTIORARI QUASHING THE APPROVAL PASSED UNDER SECTION 151 OF THE ACT DATED 25.02.2023 BEARING DIN NO.ITBA/AST/S/118/2022-23/1050126717(1) HEREIN MARKED AS ANNEXURE-A2 AND ETC. THIS PETITION COMING ON FOR ORDERS THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:38246 WP No. 23938 of 2025 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the approval passed under section 151 of the Act dated 25.02.2023 bearing DIN No.ITBA/AST/S/118/2022- 23/1050126717(1) herein marked as Annexure - A2. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed under section 148A(d) of the Act dated 27.02.2023 bearing DIN No.ITBA/AST/F/148A/2022- 23/1050154334(1) herein marked as Annexure - A3. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 148 of the Act dated 08.03.2023 bearing DIN No.ITBA/AST/S/148_1/2022- 23/1050503567(1) herein marked as Annexure - A4. iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the assessment order dated 20.03.2024 passed under section 147 rws 144 rws 144B of the Act for the assessment year 2019-20 by the Respondent No.1 bearing DIN No.ITBA/AST/S/147/2023-24/1062991022(1) herein marked as Annexure - A5. v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 20.03.2024 issued by the Respondent No.1 bearing DIN & Document No.ITBA/AST/S/319/2023-24/1062991080(1) herein marked as Annexure - A6. - 4 - HC-KAR NC: 2025:KHC:38246 WP No. 23938 of 2025 vi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand issued under section 156 of the Act dated 20.03.2024 bearing DIN & Notice No.ITBA/AST/S/156/2023-24/1062991131(1) herein marked as Annexure - A7. vii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 10.04.2024 passed under section 272A(1)(d) of the Act bearing DIN No. ITBA/PNL/F/272A(1)(d)/2024-25/1064039758(1) herein marked as Annexure - B1. viii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 10.04.2024 issued by the Respondent No.1 bearing DIN & Order No. ITBA/PNL/S/272A(1)(d)_FL/2023-24/1057282890 (1) herein marked as Annexure B2. ix) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand issued by the Respondent No.1 under section 156 of the Act dated 10.04.2024 bearing DIN & Notice No.ITBA/PNL/S/156/2024-25/1064035654(1) herein marked as Annexure - B3. x) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 09.09.2024 passed under section 271B of the Act bearing DIN No.ITBA/PNL/F/271B/2024- 25/1068483668(1) herein marked as Annexure - B4. xi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 09.09.2024 issued by the Respondent No.1 bearing DIN & Order No.ITBA/PNL/S/271B/2023-24/1062991117(1) herein marked as Annexure- B5. xii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand issued by the Respondent No.1 under section 156 - 5 - HC-KAR NC: 2025:KHC:38246 WP No. 23938 of 2025 of the Act dated 09.09.2024 bearing DIN & Notice No.ITBA/PNL/S/156/2024-25/1068483353(1) herein marked as Annexure - B6. xiii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 11.09.2024 passed under section 271AAC(1) of the Act bearing DIN No. ITBA/PNL/F/271AAC(1)/2024-25/1068584011(1), herein marked as Annexure - B7. xiv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 11.09.2024 issued by the Respondent No.1 bearing DIN & Order No. ITBA/PNL/S/271AAC(1)/2023-24/1062991141(1) herein marked as Annexure - B8. xv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand issued by the Respondent No.1 under section 156 of the Act dated 11.09.2024 bearing DIN & Notice No.ITBA/PNL/S/156/2024-25/1068577404(1) herein marked as Annexure - B9. xvi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 17.09.2024 passed under section 270A of the Act bearing DIN No.ITBA/PNL/F/270A/2024- 25/1068804292(1) herein marked as Annexure - B10. xvii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 17.09.2024 issued by the Respondent No.1 bearing DIN & Order No. ITBA/PNL/S/270A/2023-24/1062991139(1) herein marked as Annexure - B11. xviii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand issued by the Respondent No.1 under section 156 of the Act dated 17.09.2024 bearing DIN & Notice No.ITBA/PNL/S/156/2024-25/1068804336(1) herein marked as Annexure - B12. - 6 - HC-KAR NC: 2025:KHC:38246 WP No. 23938 of 2025 xix) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 226(3) of the Act by the Respondent No.1 dated 06.03.2025 bearing DIN & Notice No. ITBA/COM/F/17/2024-25/1074088046(1) herein marked as Annexure - C1. xx) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 226(3) of the Act by the Respondent No.1 dated 06.03.2025 bearing DIN & Notice No. ITBA/COM/F/17/2024-25/1074088328(1) herein marked as Annexure - C2. xxi) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri.Joseph Varghese, learned counsel for the petitioner, Sri.M.Dilip, learned counsel for the respondents. 3. The grounds projected in the subject petition in support of the prayers 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: - 7 - HC-KAR NC: 2025:KHC:38246 WP No. 23938 of 2025 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 CBC List No.: 1 Sl No.: 278