- 1 - HC-KAR NC: 2025:KHC:38226 WP No. 7279 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.7279 OF 2024 (T-IT) BETWEEN: SRI. PAUL RAJAN KUMAR, S/O PAUL RAJAN L, AGED ABOUT 59 YEARS, PAN: ARGPK9134Q, RESIDING AT NO.15/1, 1ST MAIN ROAD, 4TH CROSS, CHAMARAJAPET, BANGALORE – 560 018. …PETITIONER (BY SRI. AVINASH MALLYA U, ADVOCATE) AND: 1. THE INCOME TAX OFFICER, WARD NO.5(2)(1), BMTC BUILDING, KORAMANGALA, BANGALORE – 560 095. 2. NATIONAL FACELESS ASSESSEMENT CENTRE, ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER, INCOME TAX DEPARTMENT, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:38226 WP No. 7279 of 2024 MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, JAWAHARLAL NEHRU STADIUM, DELHI – 110 003. 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3, THE OFFICE OF THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3, BMTC BUILDING, KORAMANGALA, BANGALORE – 560 095. …RESPONDENTS (BY SRI. E. I. SANMATHI., 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 A WRIT OF CERTIORARI QUASHING THE NOTICE UNDER SECTION 148A(b) OF THE ACT DATED 21/03/2022 BEARING DIN NO.ITBA/AST/F/148A(SCN)/2021-22/1041179716(1) ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2018-19 HEREIN MARKED AS ANNEXURE-A AND ETC. THIS PETITION COMING ON FOR PRELIMINARY HEARING 'B' GROUP THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:38226 WP No. 7279 of 2024 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 notice under Section 148A(b) of the Act dated 21/03/2022 bearing DIN No.ITBA/AST/F/148A(SCN)/2021-22/1041179716(1) issued by the Respondent No.1 for the assessment year 2018-19 herein marked as Annexure - A. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order under Section 148A(d) of the Act dated 31/03/2022 bearing DIN No.ITBA/AST/F/148A/2021-22/1042338339 (1) issued by the Respondent No.1 for the assessment year 2018-19 herein marked as Annexure - A1. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148 of the Act dated 31/03/2022 bearing DIN No.ITBA/AST/S/148_1/2021-22/1042361907(1) issued by the Respondent No.1 for the assessment year 2018-19 herein marked as Annexure - A2. iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed u/s 147 r.w.s 144 dated 15/03/2023 bearing ITBA/AST/S/147/2022- 23/1050803126(1) issued by the Respondent No.2 for the assessment year 2018-19 herein marked as Annexure - АЗ. v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order u/s 272A(1)(d) of the Act dated 28/08/2023 bearing DIN - 4 - HC-KAR NC: 2025:KHC:38226 WP No. 7279 of 2024 No.ITBA/PNL/F/272A(1)(d)/2023-24/1055484536(1) by the Respondent No. 2 for the assessment year 2018-19 herein marked as Annexure - A4. vi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 25/09/2023 passed u/s 270A of the Act bearing DIN and Notice No. ITBA/PNL/F/270A/2023-24/1056520514(1) by the Respondent No. 2 for the assessment year 2018-19 herein marked as Annexure - A5. vii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order u/s 271A of the Act dated 20/09/2023 bearing DIN No.ITBA/PNL/S/156/2023-24/1056336062(1) by the Respondent No. 2 for the assessment year 2018-19 herein marked as Annexure - A6. viii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order u/s 271B of the Act dated 18/09/2023 bearing DIN No.ITBA/PNL/F/271B/2023-24/1056190171(1) by the Respondent No. 2 for the assessment year 2018-19 herein marked as Annexure - A7. ix) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri.Avinash Mallya U, 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 - 5 - HC-KAR NC: 2025:KHC:38226 WP No. 7279 of 2024 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 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. - 6 - HC-KAR NC: 2025:KHC:38226 WP No. 7279 of 2024 (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.: 360