25/1065688525(1) along with Computation Sheet
Dated: 14/06/2024, bearing DIN & Notice No:
passed by the ITBA/PNL/S/156/2024-
25/1065688466(1); Respondent Authority No.3 - The
Assessment Unit, Income Tax Department, pertaining
to Assessment Year 2019-20, vide Annexure: B, B-1
& B-2 respectively; and
C. To issue a WRIT of CERTIORARI, quashing the
impugned Penalty Order Dated: 14/06/2024, under
Sec. 271AAC(1) of the Income Tax Act, 1961, bearing
DIN & Notice No: ITBA/PNL/F/271AAC(1)/2024-
25/1065644351(1) along with Computation Sheet
Dated: 14/06/2024, bearing DIN & Notice No:
ITBA/PNL/S/271AAC(1)/2023-24/1060100887(1) and
Notice of Demand Dated: 14/06/2024, under Sec. 156
of the Income Tax Act, 1961, bearing DIN & Notice
No: ITBA/PNL/S/156/2024-25/1065642162(1); passed
by the Respondent Authority No. 3 - The Assessment
Unit, Income Tax Department, pertaining to
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Assessment Year 2019-20, vide Annexure: C, C1 &
C-2 respectively,; and
D. To Issue a WRIT of CERTIORARI, quashing the
impugned Notice Dated: 21/03/2023, bearing DIN &
Notice No: ITBA/AST/S/148_1/2022-
23/1051031470(1), under Sec. 148 of the Income Tax
Act, 1961, issued by the Income Tax Officer, Ward
6(2)(1), Bangalore, in respect of the petitioner,
pertaining to Assessment Year 2019-20, Vide
ANNEXURE - F, and
E. To issue a WRIT of CERTIORARI, quashing the
impugned order dated: 21/03/2023, vide DIN No.
ITBA/AST/F/148A/2022-23/1051030727(1), under
Sec. 148A(d) of the Income Tax Act, 1961, passed by
the Income Tax Officer, Ward 6(2)(1), Bangalore, in
respect of the petitioner, pertaining to Assessment
Year 2019-20, Vide ANNEXURE - E, and
F. To issue a WRIT of CERTIORARI, quashing the
impugned Show Cause Notice dated: 02/02/2023,
vide DIN No. ITBA/AST/F/148A(SCN)/2022-
23/1049368560(1), and another Show Cause Notice
dated: 10/03/2023, vide DIN No. under Sec.
ITBA/AST/F/148A(SCN)/2022-23/1050612828(1),
148A(b) of the Income Tax Act, issued by the Income
Tax Officer, Ward 6(2)(1), Bangalore, in respect of the
petitioner, pertaining to Assessment Year 2019-20,
Vide ANNEXURE - D & D-1 respectively.
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G. To pass any such other Writ, Order or Direction as
this Hon'ble court might deem fit to be issued in the
fact and circumstances of the case 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.
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
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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:
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
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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-A,
A1, A2, B, B1, B2, C, C1, C2, F, E, D and D1 dated
25.01.2024, 25.1.2024, 25.01.2024, 14.06.2024,
14.06.2024, 14.06.2024, 14.06.2024, 14.06.2024,
14.06.2024, 21.03.2022, 21.03.2023, 02.02.2023
and 10.03.2023, 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
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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
BMC
