- 1 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 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. 107106 OF 2024 (T-IT) C/W. WRIT PETITION NO. 107107 OF 2024 (T-IT) WRIT PETITION NO. 107108 OF 2024 (T-IT) WRIT PETITION NO. 107122 OF 2024 (T-IT) WRIT PETITION NO. 107123 OF 2024 (T-IT) WRIT PETITION NO. 107124 OF 2024 (T-IT) IN W.P.NO.107106/2024 BETWEEN: PALAKSHI HANUMANTHAPPA HARTHI SON OF SHRI HANUMANTHAPPA, AGE: 58 YEARS, OCC: BUSINESS, H.NO. 01, ASHIRWAD NILAYA, AMARESHWARNAGAR, GADAG 582102. …PETITIONER (BY SRIYUTHS. HEMANTHPAI, SMT. LOCHANA S. BABU AND SHASHANK S HEGDE, ADVOCATES) AND: 1. THE INCOME TAX OFFICER WARD 1, AYAKAR KARYALAYA, GADAG 582101. 2. THE PRINCIPAL COMMISIONER OF INCOME TAX C. R. BUILDING, NAVANAGAR, HUBBALI-580025. 3. NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU VISHAL NINGAPPA PATTIHAL Digitally signed by VISHAL NINGAPPA PATTIHAL Location: High Court of Karnataka Dharwad Bench Date: 2025.12.11 12:09:57 +0530 - 2 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 STADIUM, DELHI 110003. …RESPONDENTS (BY SRI. M.THIRUMALESH AND SMT.ROOPA, ADVS.) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO STAY THE OPERATION OF THE UNSIGNED SANCTION DATED 30.03.2024 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/118/2023-24/1063713666(1) HEREIN MARKED AS ANNEXURE – A AND ETC., IN W.P.NO.107107/2024 BETWEEN: KODIGANTI VENKATARAMANA PRASAD SON OF K C KONDAIAH HOUSE NO. 76/1, WARD NO.22, NER DURUGAMMA TEMPLE, PARVTHI NAGAR, HAGARIBOMMANAGALLI, BELLARY 583101. …PETITIONER (BY SRIYUTHS. HEMANTHPAI, SMT. LOCHANA S. BABU AND SHASHANK S HEGDE, ADVOCATES) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1, AAYAKAR BHAVAN, GULBARGA, BELLARY 585105. 2. THE CHIEF COMMISSIONER OF INCOME TAX 1 CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU 560001. 3. NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWARLAL NEHRU STADIUM, DELHI 110003. …RESPONDENTS (BY SRI. M.THIRUMALESH AND SMT.ROOPA, ADVS.) - 3 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 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 NOTICE DATED 09.08.2024 ISSUED UNDER SECTION 148A(B) OF THE ACT FOR THE ASSESSMENT YEAR 2018-19 BY THE RESPONDENT NO. 1 BEARING DIN AND NOTICE NO. ITBA/AST/F/ 148A(SCN)/2024-25/1067471981(1) HEREIN MARKED AS ANNEXURE – A AND ETC., IN W.P.NO.107108/2024 BETWEEN: HIREATE VEERA REDDY SON OF HIRATE UPENDRA REDDY AGED ABOUT 41 YEARS 1-6, BC COLONY, HOLAGUNDAM MANDALAM MANDALAM PEEDDAHYTA VILLAGE KURNOOL 518346. …PETITIONER (BY SRIYUTHS. HEMANTHPAI, SMT. LOCHANA S. BABU AND SHASHANK S HEGDE, ADVOCATES) AND: 1. THE INCOME TAX OFFICER WARD-1 AND TPS AAYAKAR BHAVAN FORT STAFF ROAD,BELLARY 583102. 2. CHIEF COMMISSIONER OF INCOME TAX-1 CENTRAL REVENUE, QUEENS ROAD, BENGALURU 560001. 3. ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM DELHI 110003. …RESPONDENTS (BY SRI. M.THIRUMALESH AND SMT.ROOPA, ADVS.) - 4 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 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 NOTICE DATED 07.08.2024 ISSUED UNDER SECTION 148A(B) OF THE ACT FOR THE ASSESSMENT YEAR 2018-19 BY THE RESPONDENT NO. 1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2024-25/1067391492(1) HEREIN MARKED AS ANNEXURE –A AND ETC., IN W.P.NO.107122/2024 BETWEEN: MACHA VENKATESH SON OF SHRI RAJANNA AGED ABOUT 63 YEARS, H.NO. 106, WARD NO. 24, TAILOR STREET, BEHIND VITOBHA, TEMPLE COWL BAZAAR, BELLARY 583102. …PETITIONER (BY SRIYUTHS. HEMANTHPAI, SMT. LOCHANA S. BABU AND SHASHANK S HEGDE, ADVOCATES) AND: 1. THE INCOME TAX OFFICER WARD 1 AND TPS, AAYAKAR BHAVAN FORT, STAFF ROAD, BELLARY 583102. 2. THE CHIEF COMMISSIONER OF INCOME TAX 1 CENTRAL REVENUE, QUEENS ROAD, BENGALURU 560001. 3. ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWARLAL NEHRU STADIUM, DELHI 110003. …RESPONDENTS (BY SRI. M.THIRUMALESH AND SMT.ROOPA, ADVS.) - 5 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 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 NOTICE DATED 07.08.2024 ISSUED UNDER SECTION 148A(B) OF THE ACT FOR THE ASSESSMENT YEAR 2018-19 BY THE RESPONDENT NO.1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2024-25/1067393194(1) HEREIN MARKED AS ANNEXURE – A AND ETC., IN W.P.NO.107123/2024 BETWEEN: GANTHA NAGHI REDDY SON OF G GANGI REDDY AGED ABOUT 51 YEARS, H.NO. 75, WARD NO.2, MANDAGOWDRA STREET, NER BUS STAND VENI VEERAPURA, BELLARY 583115. …PETITIONER (BY SRIYUTHS. HEMANTHPAI, SMT. LOCHANA S. BABU AND SHASHANK S HEGDE, ADVOCATES) AND: 1. THE INCOME TAX OFFICER WARD 1 AND TPS, AAYAKAR BHAVAN FORT, STAFF ROAD, BELLARY 583102. 2. CHIEF COMMISSIONER OF INCOME TAX 1 CENTRAL REVENUE, QUEENS ROAD, BENGALURU 560001. 3. ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWARLAL NEHRU STADIUM, DELHI-110003. …RESPONDENTS (BY SRI. M.THIRUMALESH AND SMT.ROOPA, ADVS.) 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 NOTICE DATED 07.08.2024 ISSUED UNDER SECTION 148A(B) OF THE ACT FOR THE ASSESSMENT YEAR - 6 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 2018-19 BY THE RESPONDENT NO. 1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2024-25/1067391980(1) HEREIN MARKED AS ANNEXURE – A AND ETC., IN W.P.NO.107124/2024 BETWEEN: RAVI KUMAR KURUBARU SON OF MARISWAMY KURUBARU AGED ABOUT 37 YEARS, DOOR NO. 146, WARD NO.28, RAM NAGAR, NEAR KENDRIYA VIDYALAYA BANDIHATTI, BELLARY 583101. …PETITIONER (BY SRIYUTHS. HEMANTHPAI, SMT. LOCHANA S. BABU AND SHASHANK S HEGDE, ADVOCATES) AND: 1. THE IMCOME TAX OFFICER WARD 1, AND TPS, AAYAKAR BHAVAN FORT, STAFF ROAD, BELLARY 583102. 2. THE CHIEF COMMISSIONER OF INCOME TAX 1 CENTRAL REVENUE, QUEENS ROAD, BENGALURU 560001. 3. THE ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2ND FLOOR, E RAMP, JAWARLAL NEHRU STADIUM, DELHI 110003. …RESPONDENTS (BY SRI. M.THIRUMALESH AND SMT.ROOPA, ADVS.) 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 NOTICE DATED 07.08.2024 ISSUED UNDER SECTION 148A(B) OF THE ACT FOR THE ASSESSMENT YEAR 2018-19 BY THE RESPONDENT NO. 1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2024-25/1067385811(1) HEREIN MARKED AS ANNEXURE – A AND ETC. - 7 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 THESE WRIT PETITIONS, COMING ON FOR PRELIMINARY HEARING IN B GROUP THIS DAY, ORDER WAS MADE THEREIN AS UNDER: ORAL ORDER (PER: THE HON'BLE MR. JUSTICE M.NAGAPRASANNA) 1. The petitioner - Assessee in W.P. No.107106 of 2024 is before this Court seeking quashment of the unsigned sanction dated 30.03.2024 accorded under Section 151 of the Act for the AY-2020-21 by respondent No.2 vide Annexure-A and notice dated 30.03.2024 issued under Section 148 of the Act for the AY-2020-21 by respondent No.1 vide Annexure-A1; 1.1. The petitioner - Assessee in W.P. No.107107 of 2024 is before this Court seeking quashment of the notice dated 09.08.2024 issued under Section148A(b) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A, unsigned sanction dated 29.08.2024 accorded under Section 151 of the Act for the AY-2018-19 by respondent No.2 vide Annexure-A1, order dated 29.08.2024 issued under Section 148A(d) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A2, notice dated 29.08.2024 issued under Section 148 of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A3; - 8 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 1.2. The petitioner - Assessee in W.P. No.107108 of 2024 is before this Court seeking quashment of the notice dated 07.08.2024 issued under Section148A(b) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A, unsigned sanction dated 28.08.2024 accorded under Section 151 of the Act for the AY-2018-19 by respondent No.2 vide Annexure-A1, order dated 29.08.2024 issued under Section 148A(d) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A2, notice dated 29.08.2024 issued under Section 148 of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A3; 1.3. The petitioner - Assessee in W.P. No.107122 of 2024 is before this Court seeking quashment of the notice dated 07.08.2024 issued under Section148A(b) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A, unsigned sanction dated 28.08.2024 accorded under Section 151 of the Act for the AY-2018-19 by respondent No.2 vide Annexure-A1, order dated 29.08.2024 issued under Section 148A(d) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A2, notice dated 29.08.2024 issued under Section 148 of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A3; - 9 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 1.4. The petitioner - Assessee in W.P. No.107123 of 2024 is before this Court seeking quashment of the notice dated 07.08.2024 issued under Section148A(b) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A, unsigned sanction dated 28.08.2024 accorded under Section 151 of the Act for the AY-2018-19 by respondent No.2 vide Annexure-A1, order dated 29.08.2024 issued under Section 148A(d) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A2, notice dated 29.08.2024 issued under Section 148 of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A3; 1.5. The petitioner - Assessee in W.P. No.107124 of 2024 is before this Court seeking quashment of the notice dated 07.08.2024 issued under Section148A(b) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A, unsigned sanction dated 27.08.2024 accorded under Section 151 of the Act for the AY-2018-19 by respondent No.2 vide Annexure-A1, order dated 27.08.2024 issued under Section 148A(d) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A2, notice dated 27.08.2024 issued under Section 148 of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A3. - 10 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 2. Heard Sri Hemanth Pai, Sri Lochana S.Babu & Shashank S.Hegde, learned counsels appearing for the petitioner and Sri Thirumalesh & Smt Roopa, learned counsels representing the respondents in all these petitions. 3. The grounds projected in the subject petitions 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 cases at hand, the petitions deserve to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The unsigned sanction dated 30.03.2024 vide Annexure-A and notice dated 30.03.2024 vide Annexure-A1, for the AY-2020-21 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107106 of 2024 stand quashed. - 11 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 (ii) The notice dated 09.08.2024 vide Annexure-A, unsigned sanction dated 29.08.2024 vide Annexure-A1, order dated 29.08.2024 vide Anneuxre-A2, notice dated 29.08.2024 vide Annexure-A3, for the AY-2018-19 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107107 of 2024 stand quashed. (iii) The notice dated 07.08.2024 vide Annexure-A, unsigned sanction dated 28.08.2024 vide Annexure-A1, order dated 29.08.2024 vide Anneuxre-A2, notice dated 29.08.2024 vide Annexure-A3, for the AY-2018-19 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107108 of 2024 stand quashed. (iv) The notice dated 07.08.2024 vide Annexure-A, unsigned sanction dated 28.08.2024 vide Annexure-A1, order dated 29.08.2024 vide Anneuxre-A2, notice dated 29.08.2024 vide Annexure-A3, for the AY-2018-19 issued by the - 12 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107122 of 2024 stand quashed. (v) The notice dated 07.08.2024 vide Annexure-A, unsigned sanction dated 28.08.2024 vide Annexure-A1, order dated 29.08.2024 vide Anneuxre-A2, notice dated 29.08.2024 vide Annexure-A3, for the AY-2018-19 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107123 of 2024 stand quashed. (vi) The notice dated 07.08.2024 vide Annexure-A, unsigned sanction dated 27.08.2024 vide Annexure-A1, order dated 27.08.2024 vide Anneuxre-A2, notice dated 27.08.2024 vide Annexure-A3, for the AY-2018-19 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107124 of 2024 stand quashed. - 13 - HC-KAR NC: 2025:KHC-D:17597 WP No. 107106 of 2024 C/W WP No. 107107 of 2024 WP No. 107108 of 2024 WP No.107122 of 2024 WP No.107123 of 2024 WP No.107124 of 2024 (vii) Liberty is reserved to the respondents – revenue to revive the petitions in the event, the Apex Court would hold in favour of the Revenue in the matter pending before it. (viii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. (ix) 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. Sd/- (M.NAGAPRASANNA) JUDGE VNP / CT: ANB List No.: 1 Sl No.: 133