- 1 - HC-KAR NC: 2025:KHC:54655 WP No. 38526 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 19TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO.38526 OF 2025 (T-IT) BETWEEN: BENDIGANAHALLI VENKATARAMANA SATHISH GOWDA S/O. LATE VENKATARAMANA GOWDA, AGED ABOUT 56 YEARS, RESIDING AT: BENDIGANAHALLY P O, SULEBELE HOBLI, HOSKOTE TALUK, BANGALORE 560 067. …PETITIONER (BY SRI. PRAKYAT J S, AND SMT. AAKRITI, AND SRI. UDAYA KUMAR, ADVOCATES) AND: 1. UNION OF INDIA THROUGH THE SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI 110 001. 2. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560095. 3. CHIEF COMMISSIONER OF INCOME TAX, BENGALURU-1, C.R. BUILDING, QUEEN'S ROAD, BENGALURU – 560 001. Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:54655 WP No. 38526 of 2025 4. NATIONAL FACELESS ASSESSMENT CENTRE (NAFAC), THROUGH PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX (NAFAC), MAYUR BHAWAN, CONNAUGHT LANE, NEW DELHI -110 001. …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS W.P IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUITON OF INDIA PRAYING TO QUASH THE IMPUGNED NOTICE UNDER SECTION 148A(B) DATED 31.03.2025 (DIN ITBA/AST/F/148A(SCN)/2024-25/1075344824(1)) (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 ORAL ORDER In this petition, the petitioner seeks the following reliefs: “ i) Issue a Writ of Certiorari, or any other appropriate writ, order, or direction, quashing the impugned Notice Under Section 148A(b) dated: 31.03.2025 (DIN: ITBA/AST/F/148A (SCN)/2024-25/1075344824(1)) (Annexure A); ii) Issue a Writ of Certiorari, or any other appropriate writ, order, or direction, quashing the impugned Order under Section 148A(d) dated 30.05.2025 (DIN: ITBA/AST/F/148A/2025-26/1076577804(1)) (Annexure B); - 3 - HC-KAR NC: 2025:KHC:54655 WP No. 38526 of 2025 iii) Issue a Writ of Certiorari, or any other appropriate writ, order, or direction, quashing the impugned Notice under Section 148 dated 30.05.2025 (DIN: ITBA/AST/S/148/2025-26/1076579239(1)) (Annexure C) and all proceedings consequent thereto; iv) Issue an ad-interim ex-parte order staying all further proceedings pursuant to the impugned Notice u/s 148 dated 30.05.2025 (Annexure C) during the pendency of the present writ petition; v) Award the costs of this petition in favour of the Petitioner; vi) Pass any other or further order(s) as this Hon'ble Court may deem fit and proper in the interest of justice. vii) dispense with the filing of typed and certified copies of Annexures A to D; viii) dispense with the service of advance notices to the respondents;” 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 - 4 - HC-KAR NC: 2025:KHC:54655 WP No. 38526 of 2025 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. 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 - 5 - HC-KAR NC: 2025:KHC:54655 WP No. 38526 of 2025 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 - W.P.No.17352/2022 and connected matters - dated 28.08.2025. (ii) The impugned Show Cause Notices and consequential orders, notices, etc., Annexures- A, - 6 - HC-KAR NC: 2025:KHC:54655 WP No. 38526 of 2025 B and C dated 31.03.2025, 30.05.2025 and 30.05.2025 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 SV List No.: 3 Sl No.: 5