- 1 - HC-KAR NC: 2025:KHC:49792 WP No. 27406 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 27TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO.27406 OF 2024 (T-IT) BETWEEN: SMT. SUVARNA NANGA UDAY SHANKAR W/O UDAY SHANKAR REDDY AGED ABOUT 51 YEARS, RESIDING AT NO.218, 18TH ‘D’ MAIN, HAL 2ND ‘A’ STAGE, INDIRANAGAR, BANGALORE – 560 008. …PETITIONER (BY SRI. JEEVAN J. NEERALGI, ADVOCATE) AND: NATIONAL FACELESS ASSESMENT CENTER ASSESSMENT UNIT, INCOME TAX DEPARTMENT. …RESPONDENT (BY SRI. M.DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ORDER PASSED UNDER SECTION 147 R/W SECTION 144B OF THE INCOME TAX ACT, 1961 DTD. 08.03.2024 ITBA/AST/S/147/2023-2024/1062262904(1) (ANNX-A) AND CONSEQUENTIAL NOTICE UNDER SECTION 156 OF THE INCOME TAX ACT (ANNX-B). THIS PETITION, COMING ON FOR ORDER, THIS DAY, WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:49792 WP No. 27406 of 2024 ORAL ORDER In this petition, petitioner seeks the following reliefs: “i) Issue appropriate writ of certiorari, direction or order quashing the Order passed under Section 147 R/w Section 144B of the Income Tax Act, 1961 dated 08.03.2024 ITBA/AST/S/147/2023-24/1062262904(1) (Annexure-A) and consequential notice under Section 156 of the Income Tax Act (Annexure-B) in the interest of justice and equity. ii) Pass such other order as this Hon’ble Court deems fit under the circumstances of the case.” 2. Heard learned counsel for the petitioner and learned counsel for the respondent and perused the material on record. 3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitioner invited my attention to the order of the Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order. - 3 - HC-KAR NC: 2025:KHC:49792 WP No. 27406 of 2024 4. Per contra, learned counsel for the respondent submits that there is no merit in the petition and that the same is liable to be dismissed. 5. As rightly contended by the learned counsel for the petitioner, the present petition is directly and squarely covered by the decision of the Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax – W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under: "13. I, therefore, pass the following: O R D E R (i) The impugned show cause notices 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 these cases would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. - 4 - HC-KAR NC: 2025:KHC:49792 WP No. 27406 of 2024 (iv) 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." 6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of the Co-ordinate Bench of this Court in Ramachandra Reddy's case supra. 7. In the result, I pass the following: ORDER (i) The petition is allowed and disposed of in terms of the decision of the Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025. (ii) The impugned order and notice at Annexures – A and B both dated 08.03.2024 are hereby quashed. (iii) Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, subsequent to disposal of the matters pending before the Apex Court and all rival contentions - 5 - HC-KAR NC: 2025:KHC:49792 WP No. 27406 of 2024 between the parties in this regard are kept open and no opinion is expressed on the same. Sd/- (S.R.KRISHNA KUMAR) JUDGE SV List No.: 2 Sl No.: 21