- 1 - HC-KAR NC: 2025:KHC:44203 WP No. 12601 of 2023 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 31ST DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 12601 OF 2023 (T-IT) BETWEEN: PANJOS BUILDERS P. LTD., 1ST FLOOR, CONTRACT HUDE N A L WIND TUNNEL ROAD, MURUGESHALYA, BANGALORE – 560 017 PAN: AABCP0823G REPRESENTD BY MANAGING DIRECTOR SR JOSE MANI (THE PETITIONER COMPANY INCOORPORATED UNDER THE COMPANIES ACT, 1956 ALSO AT: SRI JOSE MANI S/O LATE SHRI K. I. MANI, AGED ABOUT 72 YEARS R/AT 2284, 14TH A MAIN, H A L 2ND STAGE, INDIRANAGAR BENGALURU – 560 008 …PETITIONER (BY SRI. RAVI SHANKAR S .V., ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD 5(1)(1), PREVIOUSLY WARD - 5(1)(2) BMTC BUILDNG, BANGALORE – 560 095 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 5 THE OFFICE OF THE PRINCIPAL COMMISSINER OF INCME TAX C.R. BUILDING, QUEEN’S ROAD BANGALORE – 560 001 …RESPONDENTS (BY SRI. SUSHAL TIWARI, ADVOCATE) Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:44203 WP No. 12601 of 2023 THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE UNSIGNED NOTICE UNDER SECTION 148 OF THE INCOME TAX ACT 1961 DATED 31.03.2018 BEARING NOTICE NO. ITBA/AST/S/148/2017-18/1009600891 (1) ISSUED BY THE RESPONDENT NO.1 FOR THE AY 2011-12 HEREIN MARKED AS ANNEXURE-A AND ETC., THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks for the following reliefs:- “i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the unsigned notice under Section 148 of the Income Tax Act, 1961 dated 31.03.2018 bearing Notice No. ITBA/AST/S/148/2017- 18/1009600891(1) issued by the Respondent No.1 for the assessment year 2011-12 herein marked as Annexure-A. ii) 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 of the I.T. Act, 1961 dated 24.10.2019 bearing NIL DIN issued by the Respondent No.1 for the assessment year 2011-12 herein marked as Annexure – A1. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice u/s 271(1)(c) of the Income Tax Act, 1961 18.11.2019 bearing Notice No. ITBA/PNL/S/271(1)(c)/2019- - 3 - HC-KAR NC: 2025:KHC:44203 WP No. 12601 of 2023 20/102613674(1) by the Respondent No.1 for the assessment year 2011-12 herein marked as Annexure – A2. iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 30.12.2021 issued u/s 271(1)(c) of the Income Tax Act, 1961 bearing DIN No. ITBA/PNL/F/271(1)(C)/ 2021-22/1038241732(1) by the Respondent No.1 for the assessment year 2011-12 herein marked as Annexure-A3. v) And pass such other orders as this Hon’ble Court deems fit and proper in the interest of justice and equity.” 2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 3. A perusal of the material on record will indicate that the impugned notice at Annexure-A and all further proceedings pursuant to the impugned notice deserves to be quashed along with entire proceedings at Annexures-A, A1, A2 and A3 in view of the judgment of the Division Bench in the case of Pr. Commissioner of Income Tax-2 and another Vs. M/s. Yeshoda Electricals – ITA No.261/2021 C/w. ITA No.264/2021, dated 24.09.2025. - 4 - HC-KAR NC: 2025:KHC:44203 WP No. 12601 of 2023 4. In view of the fact that in the instant case Annexure-A was not signed and in the light of the judgment of the Division Bench in the case of Pr. Commissioner of Income Tax-2 and another Vs. M/s. Yeshoda Electricals (supra), I deem it just and appropriate to dispose of the petition by quashing all further proceedings thereto. 5. In the result, I pass the following: ORDER (i) The petition is allowed and disposed of in terms of the judgment of the Division Bench in the case of Pr. Commissioner of Income Tax-2 and another Vs. M/s. Yeshoda Electricals – ITA No.261/2021 C/w. ITA No.264/2021, dated 24.09.2025 (ii) The impugned notice dated 31.03.2018 at Annexure-A, order dated 24.10.2019 at Annexure- A1, penalty notice dated 18.11.2019 at Annexure- A2 and the penalty order dated 30.12.2021 at Annexure-A3, are is hereby quashed. Sd/- (S.R.KRISHNA KUMAR) JUDGE BMC: List No.: 2 Sl No.: 17