- 1 - HC-KAR NC: 2025:KHC:37392 WP No. 12155 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 12155 OF 2025 (T-IT) BETWEEN: MALLAVARAMRAJENDRAN REDDY S/O LATE M. MOHAN RAMI REDDY AGED ABOUT 56 YEARS. RESIDING AT 406, TULIP BLOCK. REDWOOD APARTMENTS, HARALUR ROAD, BANGALORE 560 102. EMAIL ID: Rajendrareddy1608@gmail.com MOB NO.: 9845681818 …PETITIONER (BY SRI. K R PRADEEP., ADVOCATE) AND: 1. INCOME TAX OFFICER WARD 4(3)(2), BANGALORE 3RD FLOOR, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BANGALORE - 560 095 Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37392 WP No. 12155 of 2025 2. ASSESSMENT UNIT, NATIONAL E-ASSESSMENT CENTRE, INCOME TAX DEPARTMENT MINISTRY OF FINANCE, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, NEW DELHI - 110 003. 3. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA AND GOA, C.R.BUILDING, NO.1, QUEENS ROAD, BANGALORE 560 001 …RESPONDENTS (BY SRI. E.I SANMATHI, ADVOCATE) THIS W.P. IS FILED UNDER ARTILCES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE UNDER SECTION 148A(b) OF THE ACT DATED 22.03.2022 BEARING DIN ITBA/AST/F/148A(SCN)/2021- 22/1041270953(1) NO.(ANNEXURE-B) PASSED BY THE 1ST RESPONDENT FOR THE ASSESSMENT YEAR 2015-16., AND ETC. - 3 - HC-KAR NC: 2025:KHC:37392 WP No. 12155 of 2025 THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN B GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “1) Quashing the Notice under section 148A(b) of the Act dated 22.03.2022 bearing DIN ITBA/AST/F/148A(SCN)/2021-22/1041270953(1) No. (Annexure B) passed by the 1st Respondent for the assessment year 2015-16; ii) Quashing the Order under section 148A(d) of the Act dated 05.04.2022 bearing DIN ITBA/AST/F/148A/2022-23/1042511766(1) No. (Annexure C) passed by the 1st Respondent for the assessment year 2015-16; iii) Quashing the Notice under section 148 of the Act dated 05.04.2022 bearing DIN No. ITBA/AST/S/148_1/2022-23/1042518910(1) (Annexure D) passed by the 1st Respondent for the assessment year 2015-16; iv) Quashing the Assessment Order under 147 read with section 144 read with section 144B of the Act dated 01.02.2024 bearing DIN No.ITBA/AST/S/147/2023-24/1060402148(1) (Annexure E) passed by the 2nd Respondent for the assessment year 2015-16; v) Quashing the Notice of Demand under section 156 of the Act dated 01.02.2024 bearing DIN No.ITBA/AST/S/156/2023- - 4 - HC-KAR NC: 2025:KHC:37392 WP No. 12155 of 2025 24/1060402259(1)(Annexure E1) issued by the 2nd Respondent for the assessment year 2015-16; vi) Quashing the Order u/s 271(1)(b) of the Act dated 20.08.2024 bearing No.ITBA/PNL/F/271(1)(b)/ 2024-DIN 25/1067791520(1)(Annexure G) issued by the 2nd Respondent for the assessment year 2015-16; vii) Quashing the Notice of Demand under section 156 of the Act dated 20.08.2024 bearing DIN No.ITBA/PNL/S/156/2024-25/1067790704(1) (Annexure G1) issued by the 2nd Respondent for the assessment year 2015-16; viii) Quashing the Order u/s 271F of the Act dated 20.08.2024 bearing DIN No. ITBA/PNL/F/271F/ 2024-25/1067763070(1) (Annexure H) issued by the 2nd Respondent for the assessment year 2015-16; ix) Quashing the Notice of Demand under section 156 of the dated No.ITBA/PNL/S/156/2024- 25/1067757876(1) (Annexure Act 20.08.2024 bearing DIN H1) issued by the 2nd Respondentfor the assessment year 2015-16; x) Quashing the Order u/s 271(1)(c) of the Act dated 21.08.2024 bearing DIN No. ITBA/PNL/F/271(1)(c) /2024-25/1067798789(1) (Annexure J) issued by the 2nd Respondent for the assessment year 2015-16; xi) Quashing the Notice of Demand under section 156 of the Act dated 21.08.2024 bearing DIN No.ITBA/PNL/S/156/2024-25/1067796149(1) (Annexure J1) issued by the 2nd Respondent for the assessment year 2015-16; xii) Pass such other orders as this Hon'ble Court deems fit in the facts and circumstances of the case, in the interest of justice and equity." - 5 - HC-KAR NC: 2025:KHC:37392 WP No. 12155 of 2025 2. Heard Shri K.R. Pradeep., learned counsel appearing for the petitioner and Shri E.I. Sanmathi, learned counsel appearing 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 show cause notice 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 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. - 6 - HC-KAR NC: 2025:KHC:37392 WP No. 12155 of 2025 (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 JY List No.: 1 Sl No.: 83