Karnataka High Court
Smt. Munirathnamma vs The Income Tax Officer on 14 October, 2025
Author: S.R.Krishna Kumar
Bench: S.R.Krishna Kumar
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NC: 2025:KHC:40857
WP No. 27542 of 2025
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 14TH DAY OF OCTOBER, 2025
BEFORE
THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
WRIT PETITION NO. 27542 OF 2025 (T-IT)
BETWEEN:
1. SMT. MUNIRATHNAMMA,
W/O MARIYAPPA,
AGED ABOUT 36 YEARS,
RESIDING AT #E 50, 3RD CROSS
CHANNAPPA REDDY LAYOUT,
ROOPENA AGRAHARA,
BANGALORE SOUTH,
BENGALURU - 560 068.
ALSO AT NO.41, 3RD CROSS,
NGR LAYOUT, ROOPENA AGRAHARA,
BENGALURU - 560 068.
2. SMT. ASHWINI ALIA ALLALLAMMA
W/O MANI M.,
AGED ABOUT 36 YEARS,
RESIDING AT NO.29,
Digitally signed 16TH MAIN ROAD,
by CHANDANA NEAR MARIYAMMA TEMPLE,
BM MESTRIPALYA, KOARAMANGALA,
Location: High BENGALURU - 560 034.
Court of
Karnataka ALSO AT NO.126/1, RAJAPURA VILLAGE,
JIGANI HOBLI, ANEKAL TALUK,
BENGALURU URBAN DISTRICT.
3. SMT. YASHASWINI A.,
W/O SRINIVASA B V,
AGED ABOUT 28 YEARS,
RESIDING AT #54, 1ST CROSS,
1ST MAIN, NEAR KAVERAMMA TEMPLE,
BYRASANDRA, 1ST BLOCK EAST,
JAYANAGAR, BANGALORE SOUTH,
BENGALURU - 560 011.
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WP No. 27542 of 2025
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ALSO AT NO.129, RAJAPURA VILLAGE,
JIGANI HOBLI, ANEKAL TALUK,
BENGALURU URBAN DISTRICT.
...PETITIONERS
(BY SRI. SANDEEP HUILGOL, ADVOCATE)
AND:
1. THE INCOME TAX OFFICER,
WARD-4(3)(3), BANGALORE,
ROOM NO.408, 4TH FLOOR,
BMTC BUILDING 80 FEET ROAD,
6TH BLOCK, KORAMANGALA,
BENGALURU - 560 095.
2. THE PRINCIPAL CHIEF COMMISSIONER
OF INCOME TAX, KARNATAKA AND GOA
GROUND FLOOR, CR BUILDING,
NO.1 QUEENS ROAD,
BENGALURU - 560 001.
3. PRINCIPAL COMMISSIONER OF
INCOME TAX-2, BENGALURU,
C R BUILDING NO.1, QUEENS ROAD,
BENGALURU - 560 001.
4. DIRECTORATE GENERAL
OF INCOME TAX (SYSTEMS),
NEW DELHI ARA CENTRE,
GROUND FLOOR, E-2
JHANDEWALAN EXTENSION,
NEW DELHI - 110 005.
...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 IMPUGNED
NOTICE DATED 27.07.2022 BEARING NO. ITBA/COM/F/17/2022-
23/1044146092(1) ISSUED BY THE 1ST RESPONDENT UNDER
SECTION 148 OF THE INCOME-TAX ACT, 1961 FOR THE
ASSESSMENT YEAR 2015-16 (ANNEXURE 'A') AND ETC.,
THIS PETITION, COMING ON FOR ORDERS, THIS DAY,
ORDER WAS MADE THEREIN AS UNDER:
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WP No. 27542 of 2025
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CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
ORAL ORDER
In this petition, petitioner seeks for the following reliefs:
"i. Quash the impugned Notice dated 27.07.2022 bearing
Order No. ITBA/COM/F/17/2022-23/1044146092(1)
issued by the 1st Respondent under Section 148 of
the Income-Tax Act, 1961 for the Assessment Year
2015-16 (Annexure 'A');
ii. Quash the impugned Notice dated 27.07.2022 bearing
DIN & Order No. ITBA/COM/F/17/2022-
23/1044139061(1) issued by the 1st Respondent
under Section 148 of the Income-Tax Act, 1961 for the
Assessment Year 2015-16 (Annexure 'A-1');
iii. Quash the impugned Notice dated 27.07.2022 bearing
DIN Order No. ITBA/COM/F/17/2022-
23/1044160823(1) issued by the 1st Respondent
under Section 148 of the Income-Tax Act, 1961 for the
Assessment Year 2015-16 (Annexure 'A-2');
iv. Quash the Impugned Order dated 27.07.2022 bearing
DIN & Order No. ITBA/COM/F/17/2022-
23/1044146092(1) passed by the 1st Respondent
under Section 148A(d) of the Income-Tax Act, 1961
for the Assessment Year 2015-16 (Annexure 'B');
v. Quash the Impugned Order dated 27.07.2022 bearing
DIN & Order No. ITBA/COM/F/17/2022-
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23/1044139061(1) passed by the 1st Respondent
under Section 148A(d) of the Income-Tax Act, 1961
for the Assessment Year 2015-16 (Annexure 'B-1');
vi. Quash the Impugned Order dated 27.07.2022 bearing
DIN & Order No. ITBA/COM/F/17/2022-
23/1044160823(1) passed by the 1st Respondent
under Section 148A(d) of the Income-Tax Act, 1961
for the Assessment Year 2015-16 (Annexure 'B-2');
vii. Quash the Impugned Assessment Order dated
26.05.2023 bearing DIN & Order No.
ITBA/AST/S/147/2023-24/1053228134(1) passed by
the 1st Respondent under Section 147 r.w.s 144 of the
Income-Tax Act, 1961 for the Assessment Year 2015-
16 (Annexure 'C');
viii. Quash the Impugned Assessment Order dated
26.05.2023 bearing DIN & Order No.
ITBA/AST/S/147/2023-24/1053228529(1) passed by
the 1st Respondent under Section 147 r.w.s 144 of the
Income-Tax Act, 1961 for the Assessment Year 2015-
16 (Annexure 'C-1');
Ix. Quash the Impugned Assessment Order dated
26.05.2023 bearing DIN Order No.
ITBA/AST/S/147/2023-24/1053228274(1) passed by
the 1st Respondent under Section 147 r.w.s 144 of the
Income-Tax Act, 1961 for the Assessment Year 2015-
16 (Annexure 'C-2');
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x. Quash the Impugned Penalty Order dated 21.09.2023
bearing DIN No. ITBA/PNL/F/271(1)(b)/2023-
24/1056394484(1) passed by the 1st Respondent
under Section 271(1)(b) of the Income-Tax Act, 1961
for the Assessment Year 2015-16 (Annexure 'D');
xi. Quash the Impugned Penalty Order dated 21.09.2023
ITBA/PNL/F/271(1)(b)/2023-bearing DIN No.
24/1056394487(1) passed by the 1st Respondent
under Section 271(1)(b) of the Income-Tax Act, 1961
for the Assessment Year 2015-16 (Annexure 'D-1');
xii. Quash the Impugned Penalty Order dated 21.09.2023
bearing DIN No. ITBA/PNL/F/271(1)(b)/2023-
24/1056394481(1) passed by the 1st Respondent
under Section 271(1)(b) of the Income-Tax Act, 1961
for the Assessment Year 2015-16 (Annexure 'D-2');
xiii. Quash the Impugned Penalty Order dated 22.09.2023
DIN No. ITBA/PNL/F/271F/2023-bearing
24/1056437347(1) passed by the 1st Respondent
under Section 271F of the Income-Tax Act, 1961 for
the Assessment Year 2015-16 (Annexure 'E');
xiv. Quash the Impugned Penalty Order dated 22.09.2023
No. ITBA/PNL/F/271F/2023-bearing DIN
st
24/1056437381(1) passed by the 1 Respondent
under Section 271F of the Income-Tax Act, 1961 for
the Assessment Year 2015-16 (Annexure 'E-1');
xv. Quash the Impugned Penalty Order dated 22.09.2023
bearing DIN No. ITBA/PNL/F/271F/2023-
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24/1056437436(1) passed by the 1st Respondent
under Section 271F of the Income-Tax Act, 1961 for
the Assessment Year 2015-16 (Annexure 'E-2');
xvi. Quash the Impugned Penalty Order dated 06.11.2023
bearing DIN No. ITBA/PNL/F/271(1)(c)/2023-
24/1057737061(1) passed by the 1st Respondent
under Section 271(1)(c) of the Income-Tax Act, 1961
for the Assessment Year 2015-16 (Annexure 'F');
xvii. Quash the Impugned Penalty Order dated 06.11.2023
bearing DIN No. ITBA/PNL/F/271(1)(c)/2023-
24/1057736310(1) passed by the 1st Respondent
under Section 271(1)(c) of the Income-Tax Act, 1961
for the Assessment Year 2015-16 (Annexure 'F-1');
xviii. Quash the Impugned Penalty Order dated 06.11.2023
bearing DIN No. ITBA/PNL/F/271(1)(c)/2023-
24/1057736309(1) passed by the 1st Respondent
under Section 271(1)(c) of the Income-Tax Act, 1961
for the Assessment Year 2015-16 (Annexure 'F-2');
xix. Pass such other orders or directions as this Hon'ble
Court may deem fit 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
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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
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
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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).
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 -
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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, D, D1, D2, E, E1, E2,
F, F1 and F2 dated 27.07.2022, 27.07.2022,
27.07.2022, 27.07.2022, 27.07.2022, 27.07.2022,
26.05.2023, 26.05.2023, 26.05.2023, 21.09.2023,
21.09.2023, 21.09.2023, 22.09.2023, 22.09.2023,
06.11.2023, 06.11.2023, and 06.11.2023
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
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
