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Karnataka High Court
Mr Annam Lakshminarayana Sundarraj vs Assessment Unit on 8 December, 2025
Author: S.R.Krishna Kumar
Bench: S.R.Krishna Kumar
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NC: 2025:KHC:51703
WP No. 34718 of 2025
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 8TH DAY OF DECEMBER, 2025
BEFORE
THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
WRIT PETITION NO. 34718 OF 2025 (T-IT)
BETWEEN:
1. MR ANNAM LAKSHMINARAYANA SUNDARRAJ
S/O A LAKSHMI NARAYANA SETTY,
AGED ABOUT 62 YEARS,
R/AT C-302, SANDHYA NIWAS
APARTMENT NO. 281/9,
9TH MAIN, 34TH CROSS,
JAYANAGAR, 4TH BLOCK,
JAYANAGAR III BLOCK S.O.,
BANGALORE - 560011
ALSO AT-
NO.13, 1ST MAIN ROAD,
KALAPPA BLOCK,
SRIRAMPURAM,
BANGALORE - 560021
Digitally signed
by ALSO AT-
SHARADAVANI
B FLAT NO. 2 AND 3, COMFORT CASTLE,
Location: High
Court of KANAKAPURA ROAD,
Karnataka BASAVANAGUDI,
BANGALORE - 560004
...PETITIONER
(BY SRI. SANDEEP HUILGOL, ADVOCATE)
AND:
1. ASSESSMENT UNIT
NATIONAL FACELESS ASSESSMENT CENTRE,
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NC: 2025:KHC:51703
WP No. 34718 of 2025
HC-KAR
INCOME TAX DEPARTMENT,
2ND FLOOR,
JAWAHARLAL NEHRU STADIUM,
NEW DELHI - 110003
2. COMMISSIONER OF INCOME-TAX (APPEALS)
NATIONAL FACELESS APPEAL CENTRE,
INCOME-TAX DEPARTMENT,
ROOM NO. 245-A, NORTH BLOCK,
NEW DELHI - 110001
3. INCOME TAX OFFICER
WARD 2(2) (1), BANGALORE,
BMTC BUILDING,
80 Q FEET ROAD,
6TH BLOCK,
KORAMANGALA,
BANGALORE - 590095
4. PRINCIPAL COMMISSIONER OF INCOME TAX
BENGALURU-II, BENGALURU,
C R BUILDING,
NO.1, QUEENS ROAD,
BANGALORE - 560001
...RESPONDENTS
(BY SRI. E.I. SANMATHI, ADVOCATE)
THIS WP IS FILED UNDER ARTICLE 226 OF THE
CONSTITUTION OF INDIA PRAYING TO QUASHING THE IMPUGNED
APPEAL ORDER DATED 12.02.2025 BEARING DIN AND NOTICE NO.
ITBA/NFAC/S/250/2024- 25/1073161991(1) ISSUED BY 2ND
RESPONDENT UNDER SECTION 250 OF THE INCOME-TAX ACT,
1961 FOR ASSESSMENT YEAR 2018- 19 (ANNEXURE A) AND ETC.
THIS PETITION, COMING ON FOR PRELIMINARY HEARING -
B GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:
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NC: 2025:KHC:51703
WP No. 34718 of 2025
HC-KAR
CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
ORAL ORDER
In this petition, petitioner seeks the following reliefs:
"(i) Quashing the impugned Appeal order dated
12.02.2025 bearing DIN & Notice No.
ITBA/NFAC/S/250/2024-25/1073161991(1) issued by 2nd
Respondent under Section 250 of the Income-Tax Act, 1961
for Assessment Year 2018-19 (Annexure 'A');
(ii) Quashing the impugned notice dated
31.03.2022 bearing DIN & Notice No.
ITBA/AST/S/148_1/2021-22/1042384301(1) issued by 3rd
Respondent under Section 148 of the Income-Tax Act, 1961
for Assessment Year 2018-19 (Annexure 'B');
(iii) Quashing the impugned order dated
31.03.2022 bearing no. ITBA/AST/F/148A/2021-
rd
22/1042376204(1) passed by 3 Respondent under Section
148A(d) of the Income-Tax Act, 1961 for Assessment Year
2018-19 (Annexure 'B-1');
(iv) Quashing the Impugned Show Cause Notice
dated 06.11.2025 bearing DIN No.
ITBA/AST/F/144(SCN)/202526/1082349968
(1) issued by the 1st Respondent under various relevant
provisions of the Income-Tax Act, 1961 for the Assessment
Year 2018-19 (Annexure 'M');
(v) 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."
NC: 2025:KHC:51703
HC-KAR
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
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HC-KAR
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:
ORDER
(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.
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HC-KAR
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 appeal order, impugned notice,
impugned order and the impugned show cause
notice at Annexure - A dated 12.02.2025,
Annexure - B dated 31.03.2022, Annexure - B1
dated 31.03.2022, and Annexure - M dated
06.11.2025 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
SJK
List No.: 2 Sl No.: 124
