- 1 - HC-KAR NC: 2025:KHC:51903 WP No. 36660 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 9TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 36660 OF 2025 (T-IT) BETWEEN: 1. MANJUNATH RAMESH NAYAK REPRESENTED BY GENERAL POWER OF ATTORNEY HOLDER RAJAGOPAL SHRIRANGA NAYAK AGED ABOUT 56 YEARS 208, SAPTHAGIRI RESIDENCY 3 4TH CROSS, YALLAPPA GARDEN BANASHANKARI 3RD STAGE BANGALORE -560085, KARNATAKA …PETITIONER (BY SRI. PRANAAV G. AMBEKAR, ADVOCATE) AND: 1. THE INCOME TAX OFFICER INTERNATIONAL TAXATION, WARD 1(2) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU KARNATAKA-560095. 2. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION NEW DELHI-110001. …RESPONDENTS (BY SRI. SUSHAL TIWARI, ADVOCATE) Digitally signed by CHAITHRA A Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:51903 WP No. 36660 of 2025 THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO QUASH THE ASSESSMENT ORDER DATED 22.04.2024 PASSED UNDER SECTION 147 R.W.S 144 OF THE ACT FOR THE ASSESSMENT YEAR 2016-17 BY THE RESPONDENT NO.1 BEARING DIN NO. ITBA/AST/S/147/2024-25/1064271914(1) HEREIN MARKED AS ANNEXURE - A1 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 direction in the nature of a writ of certiorari quashing the assessment order dated 22.04.2024 passed under section 147 r.w.s 144 of the Act for the Assessment Year 2016-17 by the Respondent No.1 bearing DIN DIN No.ITBA/AST/S/147/2024- 25/1064271914(1) marked as Annexure- A1. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 22.04.2024 for the Assessment Year 2016-17 issued by the Respondent No.1 ITBA/AST/S/114/2024-bearing DIN & Document No.25/1064271954(1) herein marked as Annexure - A2. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand issued under section 156 of the Act dated 22.04.2024 for the Assessment Year 2016-17 by the Respondent No.1 bearing DIN & Notice No.ITBA/AST/S/156/2024- 25/1064271967(1) herein marked as Annexure - A3. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 11.03.2025 passed under section 271F of the Act for the Assessment Year 2016-17 by the Respondent No.1 bearing DIN No - 3 - HC-KAR NC: 2025:KHC:51903 WP No. 36660 of 2025 ITBA/PNL/F/271F/2024-25/1074346384(1) herein marked as Annexure-A4. e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 11.03.2025 pertaining to penalty levied under section 271F of the Act for the Assessment Year 2016-17 issued by the Respondent No.1 bearing DIN No.2024201640420152461 T herein marked as Annexure-A5. f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the demand notice dated 11.03.2025 issued under section 156 of the Act pertaining to penalty levied under section 271F of the Act by the Respondent No.1 for the Assessment Year 2016-17 bearing DIN & Notice No. ITBA/PNL/S/156/2024-25/1074345295(1) herein marked as Annexure - A6. g)Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order dated 11.03.2025 passed under section 271(1)(c) of the Act for the Assessment Year 2016-17 by the Respondent No.1 bearing DIN No.ITBA/PNL/F/271(1)(c)/2024- 25/1074759857(1) herein marked as Annexure - A7. h) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 11.03.2025 pertaining to penalty levied under section 271(1)(c) of the Act for the Assessment Year 2016-17 issued by the Respondent No.1 bearing DIN No. 2024201640420156580T herein marked as Annexure - A8. i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the demand notice dated 11.03.2025 issued under section 156 of the Act pertaining to penalty levied under section 271(1)(c) of the Act for the Assessment Year 2016-17 by the Respondent No.1 bearing DIN & Notice No. ITBA/PNL/S/156/2024- 25/1074759406(1) herein marked as Annexure - A9. j) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 19.03.2023 issued under section 148A(b) of the Act for the Assessment Year 2016-17 by Respondent No.1 bearing DIN the & Notice No. - 4 - HC-KAR NC: 2025:KHC:51903 WP No. 36660 of 2025 ITBA/AST/F/148A(SCN)/2022-23/1050959726(1) herein marked as Annexure - B1. k) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 31.03.2023 passed under section 148A(d) of the Act for the Assessment Year 2016-17 by the Respondent No.1 bearing DIN & Order No. ITBA/AST/F/148A/2022-23/1051726327(1) herein marked as Annexure - B2. l) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 31.03.2023 issued under section 148 of the Act for the Assessment Year 2016-17 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/148_1/2022-23/1051726417(1) herein marked as Annexure B3. m) 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. 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. - 5 - HC-KAR NC: 2025:KHC:51903 WP No. 36660 of 2025 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 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. - 6 - HC-KAR NC: 2025:KHC:51903 WP No. 36660 of 2025 (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. 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-A1, A2, A3, A4, A5, A6, A7, A8, A9, B1, B2 and B3 dated 22.04.2024, 22.04.2024, 22.04.2024, 11.03.2025, 11.03.2025, 11.03.2025, 11.03.2025, 11.03.2025, 11.03.2025, 19.03.2023, 31.03.2023 and 31.03.2023 respectively are hereby quashed. - 7 - HC-KAR NC: 2025:KHC:51903 WP No. 36660 of 2025 (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 NBM List No.: 2 Sl No.: 11