- 1 - HC-KAR NC: 2025:KHC:54074 WP No. 37991 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 16TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 37991 OF 2025 (T-IT) BETWEEN: DIWAKAR N. S/O OF SRI B. NAGRAJ AGED ABOUT 35 YEARS, NO. 37/20/6, 11TH CROSS, 3RD B MAIN, HEALTH LAYOUT, SG KAVAL, BENGALURU – 560 091 …PETITIONER (BY SRI. SHREEHARI KUTSA, ADVOCATE) AND: 1. INCOME TAX OFFICER WARD 6(2)(1), BENGALURU BMTC BUILDING, 80 FT ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU – 560 095 2. PRINCIPAL CHIEF COMMISSIONER OF INCOME-TAX, KARNATAKA AND GOA, THE SPECIFIED AUTHORITY UNDER SECTION 116 OF THE INCOME TAX ACT, 1961 CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU – 560 001 3. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), A CENTER DESCRIBED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI – 110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC) Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:54074 WP No. 37991 of 2025 4. ASSESMENT UNIT A UNIT CREATED SECTION 1448 OF THE INCOME TAX ACT, 1961 ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI – 1100 03 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC)\ 5. NATIONAL FACELESS APPEAL CENTRE (NFAC) THE APPELLATE AUTHORITY UNDER THE INCOME TAX ACT, 1961, ROOM NO.401, 'C' BLOCK, CIVIC CENTRE, DELHI – 110 002 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR ANY OTHER SUITABLE WRIT FOR QUASHING OF THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED SHOW CAUSE NOTICE U/S 148A(b) OF THE INCOME TAX ACT, 1961 DATED 17/03/2022 ISSUED BY THE RESPONDENT NO. 1 TO THE PETITIONER FOR THE ASSESSMENT YEAR 2015-16 WHICH BEARS THE DIN VIZ., ITBA/AST/F/148A(SCN)/2021-22/1040947624(1)AND ENCLOSED AS ANNEXURE-C AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, the petitioner seeks the following reliefs: a. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated show cause notice u/s 148A(b) of the Income Tax Act, 1961 dated 17/03/2022 issued by the Respondent No. 1 to the Petitioner for the Assessment - 3 - HC-KAR NC: 2025:KHC:54074 WP No. 37991 of 2025 Year 2015-16 bears which the DIN viz., ITBA/AST/F/148A(SCN)/2021-22/1040947624(1)and enclosed as Annexure C b. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated order u/s 148A(d) of the Income Tax Act, 1961 dated 30/03/2022 issued by the Respondent No. 1 to the Petitioner for the Assessment Year 2015-16 which bears the DIN viz., ITBA/AST/F/148A/2021- 22/1042037227(1) and enclosed as Annexure D c. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated order u/s 148 of the Income Tax Act, 1961 dated 30/03/2022 issued by the Respondent No. 1 to the Petitioner for the Assessment Year 2015-16 which bears the DIN viz., ITBA/AST/S/148_1/2021-22/1042105372(1) and enclosed as Annexure E. d. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated assessment order u/s 147 r.w.s 144 r.w.s. 144B of the Income Tax Act, 1961 dated 16/03/2023 issued by the Respondent No. 4 to the Petitioner for the Assessment Year 2015-16 which bears the DIN viz., ITBA/AST/S/147/2022-23/1050839507(1) and enclosed as Annexure F1. e. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically - 4 - HC-KAR NC: 2025:KHC:54074 WP No. 37991 of 2025 communicated Computation Sheet dated 16/03/2023 issued by the Respondent No. 4 to the Petitioner for the Assessment Year 2015-16 which bears the DIN viz., ITBA/AST/S/114/2022-23/1050839599(1) and enclosed as Annexure F2 f. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice of demand u/s 156 of the Income Tax Act, 1961 dated 16/03/2023 issued by the Respondent No. 4 to the Petitioner for the Assessment Year 2015-16 which bears the DIN viz., ITBA/AST/S/156/2022- 23/1050839616(1) and enclosed as Annexure F3 g. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice under section 274 r.w.s 270A of the Income Tax Act, 1961 dated 16/03/2023 issued by the Respondent No. 1 to the Petitioner for the assessment year 2015-16 which bears the DIN viz., ITBA/PNL/S/270A/2022-23/1050839686(1)and enclosed as Annexure F4. h. Issue appropriate direction to the Respondent No.5 to dispose the appeal bearing Acknowledgment No. 117285410150423 15/10239719 in terms of the judgment of this Hon'ble Enclosed.cf ANNEXUREOJIJI Court in W.P.17352/2022 by reserving liberty as provided in said judgment. - 5 - HC-KAR NC: 2025:KHC:54074 WP No. 37991 of 2025 i. Grant such other reliefs as this Hon'ble Court deems fit in this matter including but not limited to cost of this petition. 2. Heard learned counsel for the petitioner and learned counsel for the respondents 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 a 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. 4. Per contra, learned counsel for the respondents 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 a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of - 6 - HC-KAR NC: 2025:KHC:54074 WP No. 37991 of 2025 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. (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 co-ordinate Bench of this Court in Ramachandra Reddy's case supra. - 7 - HC-KAR NC: 2025:KHC:54074 WP No. 37991 of 2025 7. In the result, I pass the following: ORDER (i) The petition is allowed and disposed of in terms of the decision of a 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 show cause notices and consequential orders, notices etc., at Annexures- C, D, E, F1, F2, F3 and F4 dated 17.03.2022, 30.03.2022, 30.03.2022, 16.03.2023, 16.03.2023, 16.03.2023 and 16.03.2023 respectively 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 between the parties in this regard are kept open and no opinion is expressed on the same. SD/- (S.R.KRISHNA KUMAR) JUDGE MDS List No.: 2 Sl No.: 20