- 1 - HC-KAR NC: 2025:KHC:39449 WP No. 9067 of 2023 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. 9067 OF 2023 (T-IT) BETWEEN: SRI MAHENDRA KUMAR S/O SRI PREMCHAND AGED ABOUT 44 YEARS PROPRIETOR PARAS MARKETING NO. 182, 1ST FLOOR MYSORE ROAD BENGALURU – 560 026. …PETITIONER (BY SRI ANNAMALAI S., ADVOCATE) AND: 1. ASSESSMENT UNIT INCOME TAX DEPARTMENT NATIONAL FACELESS ASSESSMENT CENTRE REPRESENTED BY ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME-TAX/ INCOME-TAX OFFICER MINISTRY OF FINANCE ROOM NO. 401, 2ND FLOOR, E-RAMP JAWAHARLAL NEHRU STADIUM DELHI - 110 003. 2. THE INCOME TAX OFFICER WARD 5(2)(1) Digitally signed by NAGAVENI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:39449 WP No. 9067 of 2023 BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU – 560 095. …RESPONDENTS (BY SRI Y.V.RAVIRAJ AND SRI M.DILIP, ADVOCATES) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ASSESSMENT ORDER PASSED UNDER SECTION 147 R.W.S 144B OF THE ACT DTD. 18.03.2023 BEARING DIN NO. ITBA/AST/S/147/2022-23/1050953358(1) ISSUED BY THE R1 FOR THE AY.2018-19 HEREIN MARKED AS ANNX-A12; QUASH THE COMPUTATION SHEET DTD.18.03.2023 BEARING DIN AND DOCUMENT NO. ITBA/AST/S/183/2022-23/1050953483(1) ISSUED BY THE R1 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-A2; QUASH THE DEMAND NOTICE DTD. 18.03.2023 ISSUED UNDER SECTION 156 OF THE ACT BEARING DIN AND NOTICE NO. ITBA/AST/S/156/2022-23/1050953545(1) BY THE R1 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-A3; QUASH THE PENALTY NOTICE UNDER SECTION 274 R.W.S 271AAC(1) OF THE ACT DTD.19.03.2023 BEARING DIN NO. ITBA/PNL/S/271AAC(1)/2022-23/1050952641(1) BY THE R1 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-A4; QUASH THE PENALTY NOTICE U/S 274 R.W.S. 270A OF THE ACT DTD. 19.03.2022 BEARING DIN NO. ITBA/PNL/S/270A/2022- 23/1050952620(1) BY THE R1 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-A5; QUASH THE NOTICE U/S 148A(D) OF THE ACT DTD.15.03.2022 BEARING DIN NO. ITBA/AST/F/148A(SCN)/2021-22/1040767295(1) BY THE R2 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-B1; QUASH THE ORDER PASSED U/S 148A(D) OF THE ACT DTD. 30.03.2022 BEARING DIN NO. ITBA/AST/F/148A/2021- 22/1042195626(1) BY THE R2 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-B2; QUASH THE NOTICE U/S 148 OF THE ACT DTD. 31.03.2022 BEARING DIN NO. ITBA/AST/S/148_1/2021-22/1042353258(1) BY THE R2 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-B3. - 3 - HC-KAR NC: 2025:KHC:39449 WP No. 9067 of 2023 THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/AST/S/156/2022- 23/1050953545(1) dated 18.03.2023, ITBA/PNL/S/271AAC(1)/2022-23/1050952641(1) dated 19.03.2023, ITBA/PNL/S/270A/2022-23/1050952620(1) dated 19.03.2023, ITBA/AST/F/148A(SCN)/2021-22/1040767295(1) dated 15.03.2022, ITBA/AST/S/148_1/2021- 22/1042353258(1) dated 31.03.2022, computation sheet DIN and document No.ITBA/AST/S/183/2022-23/1050953483(1) dated 18.03.2023 and order Nos.ITBA/AST/S/147/2022- 23/1050953358(1) dated 18.03.2023, ITBA/AST/F/148A/2021- 22/1042195626(1) dated 30.03.2022 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:39449 WP No. 9067 of 2023 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri Y.V.Raviraj and Sri M. Dilip, 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/S/156/2022-23/1050953545(1) dated 18.03.2023, ITBA/PNL/S/271AAC(1)/2022- 23/1050952641(1) dated 19.03.2023, ITBA/PNL/S/270A/2022-23/1050952620(1) dated 19.03.2023, ITBA/AST/F/148A(SCN)/2021- 22/1040767295(1) dated 15.03.2022, ITBA/AST/S/148_1/2021-22/1042353258(1) dated 31.03.2022, computation sheet DIN and document No.ITBA/AST/S/183/2022-23/1050953483(1) dated - 5 - HC-KAR NC: 2025:KHC:39449 WP No. 9067 of 2023 18.03.2023 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 NVJ List No.: 1 Sl No.: 331 CT:SS