Mr Laxman Purohit vs Assessment Unit
2025 Latest Caselaw 10180 Kant

Karnataka High Court

Mr Laxman Purohit vs Assessment Unit on 13 November, 2025

Author: S.R.Krishna Kumar

Bench: S.R.Krishna Kumar

                                             -1-
                                                          NC: 2025:KHC:46301
                                                        WP No. 33930 of 2025


                HC-KAR



                    IN THE HIGH COURT OF KARNATAKA AT BENGALURU

                         DATED THIS THE 13TH DAY OF NOVEMBER, 2025

                                          BEFORE
                     THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
                            WRIT PETITION NO. 33930 OF 2025 (T-IT)


               BETWEEN:

               MR. LAXMAN PUROHIT
               SON OF LASAJI PUROHIT
               AGED ABOUT 39 YEARS
               R/A NO-348/1, 2ND FLOOR,
               PAWAR MANSION
               NEW THIPPASANDRA MAIN ROAD,
               HAL 3RD STAGE,
               BENGALURU - 560075.

               ALSO AT-SHOP NO. 2, DOOR NO. 1891,
               1ST MAIN, 8TH CROSS, HAL III STAGE
               (BEML MAIN ROAD),
               BENGALURU - 560075
Digitally signed
by JUANITA                                                      ...PETITIONER
THEJESWINI       (BY SRI. SANDEEP HUILGOL., ADVOCATE)
Location: HIGH
COURT OF         AND:
KARNATAKA

               1.   ASSESSMENT UNIT
                    NATIONAL FACELESS ASSESSMENT CENTRE
                    INCOME TAX DEPARTMENT,
                    2ND FLOOR, JAWAHARLAL NEHRU STADIUM,
                    NEW DELHI 110003.

               2.   INCOME TAX OFFICER,
                    WARD 4(2)(1), BANGALORE,
                                -2-
                                            NC: 2025:KHC:46301
                                         WP No. 33930 of 2025


 HC-KAR



     BMTC BUILDING, 80 FEET ROAD,
     6TH BLOCK, KORAMANGALA,
     BENGALURU - 560095.

3.   PRINCIPAL CHIEF COMMISSIONER
     OF INCOME TAX
     BENGALURU-2, BENGALURU
     C R BUILDING, NO.1, QUEENS ROAD
     BENGALURU-560001.

4.   TAX RECOVERY OFFICER-2
     BENGALURU
     BMTC BUILDING, 80 FEET ROAD
     6TH BLOCK, KORAMANGALA
     BENGALURU-560095.
                                              ...RESPONDENTS
(BY SRI. E.I. SANMATHI., ADVOCATE FOR R1 TO R4)

      THIS   WP   IS   FILED   UNDER    ARTICLE   226   OF   THE
CONSTITUTION OF INDIA PRAYING TO QUASHING THE IMPUGNED
NOTICE DATED 29.03.2022 BEARING DIN AND NOTICE NO.
ITBA/AST/S/148 1/2021-22/1041889625(1) ISSUED BY RESPONDENT
NO. 2 UNDER SECTION 148 OF THE INCOME- TAX ACT, 1961 FOR
ASSESSMENT YEAR 2018-19 (ANNEXURE A) (II) QUASHING THE
IMPUGNED ORDER DATED 29.03.2022 BEARING NO. PASSED BY
ITBA/AST/F/148A/2021-22/1041881628(1)   RESPONDENT       NO.   2
UNDER SECTION 148A(D) OF THE INCOME-TAX ACT, 1961 FOR
ASSESSMENT YEAR 2018-19 (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
                                      -3-
                                                    NC: 2025:KHC:46301
                                                 WP No. 33930 of 2025


HC-KAR



                             ORAL ORDER

In this petition, the petitioner seeks for the following reliefs:

i) Quashing the impugned notice dated 29.03.2022 bearing DIN and Notice No.ITBA/AST/S/148_1/2021-

22/1041889625(1) issued by Respondent no.2 under Section 148 of the Income-Tax Act, 1961 for Assessment Year 2018-19 (Annexure A);

(ii) Quashing the impugned order dated 29.03.2022 bearing no.ITBA/AST/F/148A/2021-22/1041881628(1) passed by Respondent no.2 under Section 148A(d) of the Income-Tax Act, 1961 for Assessment Year 2018-19 (Annexure 'A1');

(iii) Quashing the impugned Assessment order dated 21.03.2023 bearing DIN no.ITBA/AST/S/147/2022- 23/1051081955(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 2018- 19 (Annexure 'B' );

(iv) Quashing the impugned Computation Sheet dated 21.03.2023 bearing DIN No.ITBA/AST/S/183/2022- 23/1051082163(1) passed by Respondent no.1 for Assessment Year 2018-19 (Annexure B1);

(v) Quashing the impugned Notice of Demand dated 21.03.2023 bearing DIN no. ITBA/AST/S/156/2022- 23/1051082270(1) issued by Respondent no. 1 under

NC: 2025:KHC:46301

HC-KAR

Section 156 of the Income-Tax Act, 1961 for Assessment Year 2018-19 (Annexure 'B2');

(vi) Quashing the impugned Penalty order dated 22.09.2023 bearing DIN no.ITBA/PNL/F/271AAC(1)/2023- 24/1056453800(1) passed by Respondent no. 1 under Section 271AAC(1) of the Income-Tax Act, 1961 for Assessment Year 2018-19 (Annexure 'C');

(vii) Quashing the impugned Computation Sheet dated 22.09.2023 passed by Respondent no. 1, bearing DIN no.ITBA/PNL/S/271AAC(1)/2022-23/1051082077(1) for Assessment Year 2018-19 (Annexure 'C1');

(viii) Quashing the impugned Notice of Demand, dated 22.09.2023 bearing DIN no. ITBA/PNL/S/156/2023- 24/1056453715(1) passed by Respondent no. 1 under Section 156 of the Income-Tax Act, 1961 for Assessment Year 2018-19 (Annexure 'C2');

(ix) Quashing the impugned Penalty order dated 27.09.2023 bearing DIN no. ITBA/PNL/F/270A/2023- 24/1056585814(1) passed by Respondent no. 1 under Section 270A of the Income-Tax Act, 1961 for assessment year 2018-19 (Annexure 'D' );

(x) Quashing the impugned Computation Sheet 27.09.2023 passed by Respondent no. 1 bearing DIN no. ITBA/PNL/S/270A/2022-23/1051082080(1) for

NC: 2025:KHC:46301

HC-KAR

Assessment Year 2018-19 (Annexure 'D1');

(xi) Quashing the Impugned Notice of Demand dated 27.09.2023 passed by Respondent no. 1 under Section 156 of the Act, bearing DIN no. ITBA/PNL/S/156/2023- 24/1056585816(1) of the Income-Tax Act, 1961 for assessment year 2018-19 (Annexure 'D2');

(xii) Quashing the impugned recovery notice of demand dated 03.09.2025 issued by Respondent no. 4, bearing DIN and document no. ITBA/RCV/S/301/2025- 26/1080294752(1) and TRC No. TRO-2, BANGALORE/ADYPL5405D/2025-26/100000792684 for Assessment Year 2018-19 (Annexure-E).

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.