- 1 - HC-KAR NC: 2025:KHC:51912 WP No. 37108 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. 37108 OF 2025 (T-IT) BETWEEN: 1. M/S BRS SERVICE STATION A PARTNERSHIP FIRM (UNDER REGISTERED INDIAN PARTNERSHIP ACT 1882) HAVING ITS REGISTERED ADDRESS AT NO.01, KIADB ROAD, OPP 3 SHED NEAR RAJAGOPALNAGAR BUS STAND PEENYA 2ND STAGE, BENGALURU KARNATAKA - 560 091. REPRESENTED BY ITS PARTNER SMT. G JAYALAKSHMI W/O S.G. GANGADHARAIAH AGED ABOUT 51 YEARS RESIDING AT NO.391, 18TH CROSS 6TH MAIN, BEML LAYOUT, 1ST STAGE BASAVESHWARANAGAR BENGALURU-560079. …PETITIONER (BY SRI. SANDEEP HUILGOL, ADVOCATE) AND: 1. ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT 2ND FLOOR, JAWAHARLAL NEHRU STADIUM NEW DELHI - 110003. Digitally signed by CHAITHRA A Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:51912 WP No. 37108 of 2025 2. INCOME TAX OFFICER WARD 6(2)(1), BANGALORE BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, KORAMANGALA BANGALORE - 590095. 3. INCOME TAX OFFICER WARD 2(1)(3), BANGALORE BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, KORAMANGALA BANGALORE - 590095. 4. PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU - I, BENGALURU C R BUILDING, NO. 1, QUEENS ROAD BANGALORE - 560001. …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA, PRAYING TO QUASH THE IMPUGNED NOTICE DATED 31.03.2023 BEARING DIN AND NOTICE NO. ITBA/AST/S/148-1/2022-23/1051816218(1) ISSUED BY RESPONDENT NO. 2 UNDER SECTION 148 OF THE INCOME TAX ACT, 1961 FOR ASSESSMENT YEAR 2019-20 (ANNEXURE A), 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:- "i. Quashing the impugned Notice dated 31.03.2023 bearing DIN & Notice No.ITBA/AST/S/148_1/2022-23/1051816218 - 3 - HC-KAR NC: 2025:KHC:51912 WP No. 37108 of 2025 (1) issued by Respondent No.2 under Section 148 of the Income-Tax Act, 1961 for Assessment Year 2019-20 (Annexure 'A'); ii. Quashing the impugned Order dated 31.03.2023 bearing no.ITBA/AST/F/148A/2022-23/1051811686(1) passed by Respondent No.2 under Section 148A(d) of the Income- Tax Act, 1961 for Assessment Year 2019-20 (Annexure 'A-1'); iii. Quashing the impugned Assessment order dated 04.03.2024 bearing DIN no.ITBA/AST/S/147/2023- 24/1061955779 (1) passed by Respondent No.1 under Section 147 read with section 144 read with section 144B of the Income-Tax Act, 1961 for Assessment Year 2019-20 (Annexure 'B'); iv. Quashing the impugned Computation Sheet dated 04.03.2024 bearing DIN no. ITBA/AST/S/519/2023- 24/1061955924 (1) issued by Respondent No.1, for Assessment Year 2019-20 (Annexure 'B-1'); v. Quashing the impugned Notice of Demand dated 04.03.2024 bearing DIN no. ITBA/AST/S/156/2023- 24/1061955891 (1) issued by Respondent No. 1 under Section 156 of the Income-Tax Act, 1961 for Assessment Year 2019-20 (Annexure 'B-2'); vi. Quashing the impugned Penalty order dated 04.09.2024 bearing DIN No. ITBA/PNL/F/272A(1)(d)/2024-25/ 1068332710(1) passed by Respondent No.1 under Section - 4 - HC-KAR NC: 2025:KHC:51912 WP No. 37108 of 2025 272A(1)(d) of the Income-Tax Act, 1961 for Assessment Year 2019-20 (Annexure 'C'); vii. Quashing the Impugned Computation Sheet dated 04.09.2024 passed by Respondent No.1, bearing DIN No.ITBA/PNL/S/272A(1)(d)_FL/2023-24/1061954537(1) for Assessment Year 2019-20 (Annexure 'C-1'); viii. Quashing the Impugned Notice of Demand dated 04.09.2024 bearing DIN по. ITBA/PNL/S/156/2024- 25/1068327779(1) passed by Respondent No.1 under Section 156 of the Income-Tax Act, 1961 for Assessment Year 2019-20 (Annexure 'C-2'); ix. Quashing the impugned Penalty order dated 06.09.2024 bearing DIN no.ITBA/PNL/F/271AAC(1)/2024-25/ 1068424028 (1) passed by Respondent No.1 under Section 271AAC(1) of the Income-Tax Act, 1961 for Assessment Year 2019-20 (Annexure 'D'); x. Quashing the impugned Computation Sheet dated 06.09.2024 passed by Respondent No.1, bearing DIN No. ITBA/PNL/S/271AAC(1)_FL/2023-24/1061956158 (1) for Assessment Year 2019-20 (Annexure 'D-1'); xi. Quashing the Impugned Notice of Demand dated 06.09.2024 bearing DIN no.ITBA/PNL/S/156/2024-25/ 1068418426(1) passed by Respondent No.1 under Section 156 of the Income-Tax Act, 1961 for Assessment Year 2019-20 (Annexure 'D-2'); - 5 - HC-KAR NC: 2025:KHC:51912 WP No. 37108 of 2025 xii. Quashing the impugned Recovery Letter dated 19.11.2025 bearing DIN & Letter no. ITBA/RCV/F/17/2025- 26/1082763943(1) issued by Respondent No.3 for Assessment Year 2019-20 (Annexure 'E'); xiii. Pass such other or further orders as this Hon'ble Court may deem fit in the facts and circumstances of the case, and in the interests 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. 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. - 6 - HC-KAR NC: 2025:KHC:51912 WP No. 37108 of 2025 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. (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." - 7 - HC-KAR NC: 2025:KHC:51912 WP No. 37108 of 2025 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 assessment order, computation sheet, notices and consequential orders, notices etc., at Annexures-B, B1, B2, C, C1, C2, D, D1, D2 and E dated 04.03.2024, 04.03.2024, 04.03.2024, 04.09.2024, 04.09.2024, 04.09.2024, 06.09.2024, 06.09.2024, 06.09.2024 and 19.11.2025 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 - 8 - HC-KAR NC: 2025:KHC:51912 WP No. 37108 of 2025 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.: 28