- 1 - HC-KAR NC: 2025:KHC-D:17556 WP No. 100943 of 2025 IN THE HIGH COURT OF KARNATAKA, AT DHARWAD DATED THIS THE 8TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 100943 OF 2025 (T-IT) BETWEEN: KONDALAHALLI CHANNABASAPPA NAGARAJA SON OF CHANNABASAPPA K., AGED ABOUT 56 YEARS, SARASWATHI NILAYA, NO. 5,6,7, KINGS STREET, OLD TOWN, VEERABHADRESHWARA TEMPLE, CHALLAKERE, CHITRADURGA – 577 522. …PETITIONER (BY SRI. HEMANT PAI AND SMT. LOCHANA S. BABU & SHASHANK S HEGDE, ADVOCATES) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HUBBALLI, C R BUILDING, NAVANAGAR, HUBBALLI – 580 025. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL, PANAJI, CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU – 560 001. …RESPONDENTS (BY SRI. M. THIRUMALESH AND SMT. ROOPA, ADVOCATES) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 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 UNSIGNED SANCTION DATED 29.03.2024 ACCORDED UNDER SECTION 151 OF THE ACT FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO. 2 BEARING DIN AND NOTICE NO. ITBA/AST/S/118/2023-24/1063645031(1) HEREIN MARKED AS ANNEXURE – A AND ETC., THIS WRIT PETITION, COMING ON FOR ORDERS THIS DAY, ORDER WAS MADE THEREIN AS UNDER: Digitally signed by RAKESH S HARIHAR Location: High Court of Karnataka, Dharwad Bench, Dharwad - 2 - HC-KAR NC: 2025:KHC-D:17556 WP No. 100943 of 2025 ORAL ORDER (PER: THE HON'BLE MR. JUSTICE M.NAGAPRASANNA) The petitioner - Assessee is before this Court seeking quashment of the unsigned sanction dated 29.03.2024 accorded under Section 151 of the Act for the AY-2020-21 by respondent No.1 vide Annexure-A and the notice dated 29.03.2024 issued under Section 148 of the Act for the AY-2020-21 by respondent Annexure-A1. 2. Heard Sri Hemanth Pai, Sri Lochana S.Babu & Shashank S.Hegde, learned counsels for the petitioner and Sri Thirumalesh & Smt Roopa, learned counsels 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: - 3 - HC-KAR NC: 2025:KHC-D:17556 WP No. 100943 of 2025 ORDER (i) The unsigned sanction dated 29.03.2024 accorded under Section 151 of the Act for the AY-2020-21 vide Annexure-A and the notice dated 29.03.2024 issued under Section 148 of the Act for the AY-2020-21 Annexure-A1, 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 VNP/CT-ASC List No.: 1 Sl No.: 137