- 1 - HC-KAR NC: 2026:KHC:25896 WP No. 10582 of 2026 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 2ND DAY OF JUNE, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 10582 OF 2026 (T-IT) BETWEEN: M/S SATYADEVA BUILDERS A PARTNERSHIP FIRM HAVING ITS REGISTERED OFFICE AT NO. 50/2, BYRASANDRA MAIN ROAD, JEEVANBHIMANAGAR BENGALURU - 560 075 REPRESENTED BY ITS PARTNER, SURENDRANATH REDDY L., R/O NO.K-4, BLOCK-2, ALPINE MEADOWS, 1ST MAIN, VIGNANA NAGAR, BENGALURU 560 075 …PETITIONER (BY SRI. HEMANT VENKATRAY PAI., ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:25896 WP No. 10582 of 2026 BENGALURU 560 095 2. PRINCIPAL COMMISSIONER OF INCOME TAX 2, C.R. BUILDING, NO. 1, QUEENS ROAD, BENGALURU 560 001 3. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, REP. BY ADDL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/INCOME TAX OFFICER, INCOME TAX DEPARTMENT, ROOM NO 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, NEW DELHI - 110 003 …RESPONDENTS (BY SRI. E. I. SANMATHI,ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE SHOW CAUSE NOTICE DATED 28.03.2024 ISSUED UNDER SECTION 148A(B) OF THE ACT FOR AY 2020-21 BY RESPONDENT NO. 1 BEARING DIN ITBA/AST/F/148A(SCN)/2023-24/1063519779(1), HEREIN ENCLOSED AND MARKED AS ANNEXURE-A; QUASH THE ORDER DATED 02.05.2024 PASSED UNDER SECTION 148A(D) OF THE ACT FOR THE AY 2020-21 BY RESPONDENT NO. 1 BEARING DIN HEREIN - 3 - HC-KAR NC: 2026:KHC:25896 WP No. 10582 of 2026 ITBA/AST/F/148A/2024-25/1064567958(1), HEREIN ENCLOSED AND MARKED AS ANNEXURE-A1; QUASH THE NOTICE DATED 02.05.2024 ISSUED UNDER SECTION 148 OF THE ACT FOR THE AY 2020-21 BY RESPONDENT NO. I BEARING DIN ITBA/AST/S/148.1/2024-25/1064568290(1), HEREIN ENCLOSED AND MARKED AS ANNEXURE-A2; QUASH THE ASSESSMENT ORDER DATED 25.02.2026 PASSED UNDER SECTION 147 R.W.S. 144B OF THE ACT FOR THE AY 2020-21 BY RESPONDENT NO. 3 BEARING DIN ITBA/AST/S/147/2025-26/1086492382(1), HEREIN ENCLOSED AND MARKED AS ANNEXURE - A3; QUASH THE PENALTY SHOW CAUSE NOTICE DATED 23.02.2026 ISSUED UNDER SECTION 272A(1)(D) OF THE ACT FOR THE AY 2020-21 BY RESPONDENT NO. 3 BEARING DIN ITBA/PNL/S/272A(1) (D)/2025- 26/1086381328(1), HEREIN ENCLOSED AND MARKED AS ANNEXURE - A4; QUASH THE PENALTY SHOW CAUSE NOTICE DATED 25.02.2026 ISSUED UNDER SECTION 270A OF THE ACT FOR THE AY 2020-21 BY RESPONDENT NO. 3 BEARING DIN ITBA/PNL/S/270A/2025-26/1086492392(1), HEREIN ENCLOSED AND MARKED AS ANNEXURE - A5. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 4 - HC-KAR NC: 2026:KHC:25896 WP No. 10582 of 2026 CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD ORAL ORDER The petitioner, a Partnership Firm engaged in the business of construction, has filed this petition calling in question the Show Cause Notice dated 02.05.2024 under Section 148A(b) of the Income Tax Act, 1961 [for short, 'the IT Act'], the order under Section 148A(d), the Assessment Order dated 25.02.2026 under Section 147 read with Section 144B of the IT Act and the subsequent penalty Show Cause Notices. The proceedings are relevant to the assessment year 2020-21. 2. Mr. Hemant Venkatray Pai, the learned counsel for the petitioner, submits that the petitioner's grievance insofar as the present petition could be redressed if this Court interferes with the Assessment Order dated 25.02.2026 and the penalty Show Cause Notices with liberty to file a detailed - 5 - HC-KAR NC: 2026:KHC:25896 WP No. 10582 of 2026 response to the Show Cause Notice dated 02.05.2024 leaving open all questions to be answered afresh by the Assessing Officer. In elaboration, the learned counsel submits that [i] the proceedings under Section 148A of the IT Act only referred to sale of one unit but the Show Cause Notice dated 03.02.2026 has referred, for the first time, to multiple units sold by the petitioner, and [ii] if the Show Cause Notice is dated 03.02.2026, the impugned order is dated 25.02.2026 allowing the petitioner only two weeks to collate all payments. 3. Mr. Hemant Venkatray Pai argues for a reasonable opportunity before the petitioner is fastened with liability. Mr. E. I Sanmathi, the learned Senior Standing counsel for the respondents, is heard for final disposal of the petition in the light of these circumstances. The petitioner is allowed time between the Show Cause Notice dated 03.02.2026 and the impugned Assessment Order dated - 6 - HC-KAR NC: 2026:KHC:25896 WP No. 10582 of 2026 25.02.2026 to respond to a deficiency in filing returns on the sale of 119 apartments but without the advantage of notice of the proceedings based on this in the proceedings under Section 148A of the IT Act. 4. This Court finds that, in these circumstances, the petitioner's case for a limited interference with the Assessment Order and the consequent penalty notices with opportunity to file response to the Show Cause Notices will be just and reasonable, especially when this Court can observe that all questions otherwise are left open for decision on restoration but based on the response that the petitioner can file within the time allowed by this Court. In the light of the afore, the following: ORDER The petition is allowed-in-part quashing the impugned Assessment Order dated 25.02.2026 and the subsequent penalty Show Cause Notices [Annexures - - 7 - HC-KAR NC: 2026:KHC:25896 WP No. 10582 of 2026 A3, A4, A5] with liberty to the petitioner to file a detailed response within four [4] weeks from today observing that the Assessing Officer shall conclude all proceedings upon due consideration of the response that is offered. SD/- (B M SHYAM PRASAD) JUDGE RB