- 1 - HC-KAR NC: 2025:KHC:37893 WP No. 32009 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.32009 OF 2024 (T-IT) BETWEEN: PURUSHOTHAMAN SUNILRAJ SON OF SRI. PURUSOTHAMAN, AGED ABOUT 59 YEARS PREVIOUSLY AT NO. 29, 1ST FLOOR, D BANUMAIAH ROAD, K.R. MOHALLA, MYSORE – 570 024 PRESENTLY RESIDING AT FLAT NO.E 704, PURVA WESTEND APTS, KUDULU GATE JUNCTIONS, KUDLU, BENGALURU – 560 068 …PETITIONER (BY SRI. SHREEHARI, ADVOCATE) AND: 1. INCOME TAX OFFICER WARD 4(3)(2) BENGALURU BMTC BUILDING, 80FT ROAD, 6TH BLOCK, KORAMANGALA, NEAR KHB GAMES VILLAGE, BENGALURU – 560 095 EMAIL BANGALORE.ITO4.3.2@INCOMETAX.GOV.IN & OTHERS 2. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KARNATAKA & GOA, BENGALURU THE SPECIFIED AUTHORITY UNDER SECTION 151 OF THE INCOME TAX ACT, 1961 CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001 Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37893 WP No. 32009 of 2024 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) …RESPONDENTS (BY SRI. E. I SANMATHI, ADVOCATE) THIS WP 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 UNDER SECTION 148A(b) OF THE INCOME TAX ACT, 1961 DATED 17/03/2023 ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2016-17 WHICH BEARS THE DIN VIZ., ITBA/AST/F/148A(SCN)/2022- 23/1050898618(1) AND ENCLOSED AS ANNEXURE F AND ETC THIS PETITION COMING ON FOR ORDERS THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:37893 WP No. 32009 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/AST/F/148A(SCN)/2022-23/1050898618(1) dated 17.03.2023, ITBA/AST/S/148_1/2022-23/1051630215(1) dated 30.03.2023, ITBA/AST/S/156/2023-24/1062020847(1) dated 05.03.2024, ITBA/PNL/S/156/2024-25/1068365886(1) dated 05.09.2024, ITBA/PNL/S/156/2024-25/1068395663(1) dated 05.09.2024, computation sheet No.ITBA/AST/S/114/2023-24/1062020874(1) dated 05.03.2024 and order Nos.ITBA/AST/F/148A/2022- 23/1051386459(1) dated 27.03.2023, ITBA/AST/S/147/2023- 24/1062020727(1) dated 05.03.2024, ITBA/PNL/F/271(1)(c)/2024-25/1068370270(1) dated 05.09.2024, ITBA/PNL/F/271F/2024-25/1068395791(1) dated 05.09.2024, passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. - 4 - HC-KAR NC: 2025:KHC:37893 WP No. 32009 of 2024 2. Heard Sri Shreehari, learned counsel for the petitioner and Sri E.I.Sanmathi, 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 notices bearing No. ITBA/AST/F/148A(SCN)/2022-23/1050898618(1) dated 17.03.2023, ITBA/AST/S/148_1/2022- 23/1051630215(1) dated 30.03.2023, ITBA/AST/S/156/2023-24/1062020847(1) dated 05.03.2024, ITBA/PNL/S/156/2024- 25/1068365886(1) dated 05.09.2024, ITBA/PNL/S/156/2024-25/1068395663(1) dated 05.09.2024, computation sheet No.ITBA/AST/S/114/2023-24/1062020874(1) dated 05.03.2024 issued by the jurisdictional Assessing - 5 - HC-KAR NC: 2025:KHC:37893 WP No. 32009 of 2024 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 and I.A.No.1/2025 would be considered, in the event revival of this petition becomes necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 405