Karnataka High Court
Nandita Anilkant Mehta vs Income Tax Officer on 29 October, 2025
Author: S.R.Krishna Kumar
Bench: S.R.Krishna Kumar
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WP No. 32231 of 2025
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IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 29TH DAY OF OCTOBER, 2025
BEFORE
THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
WRIT PETITION NO. 32231 OF 2025 (T-IT)
BETWEEN:
1. NANDITA ANILKANT MEHTA
D/O ANIKANT HANILAL LMEHTA
AGED ABOUT 50 YEARS
RESIDING AT
FLAT NO. 402B, SRINIVASA CLASSIC,
SARJAPUR MAIN ROAD,
NEXT TO FIRE STATION,
KAIKONDARAHALLI,
BANGALORRE 560 035
...PETITIONER
(BY SRI. GIRIJA G P.,ADVOCATE)
AND:
1. INCOME TAX OFFICER
Digitally signed WARD5(3)(3) BANGALORE
by
SHARADAVANI 3RD FLOOR, BMTC BUILDING,
B 80 FEET ROAD, 6TH BLOCK, KORAMANGALA
Location: High
Court of BANGALORE - 560 095
Karnataka
2. ASSESSMENT UNIT
NATIONAL E-ASSESSMENT CENTRE,
INCOME TAX DEPARTMENT,
MINISTRY OF FINANCE
2ND FLOOR, E RAMP,
JAWAHARLAL NEHRU STADIUM
NEW DELHI - 110 003
REPRESENTED BY COMMISSIONER
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3. PRINCIPAL COMMISSIONER OF INCOME TAX
BANGALORE - 3
5TH FLOOR, BMTC BUILDING
80 FEET ROAD, 6TH BLOCK
KORAMANGALA
BANGALORE - 560 095
...RESPONDENTS
(BY SRI. M. TIRUMALESH,ADVOCATE)
THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF
THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE
NOTICE UNDER SECTION 148 OF THE ACT DATED 30.03.2024
BEARING DIN NO. ITBA/AST/S/148_1/2023-24/1063711145(1)
(ANNEXURE A) ISSUED BY THE 1ST RESPONDENT FOR THE
ASSESSMENT YEAR 2020-21 AND ETC.,
THIS PETITION, COMING ON FOR FINAL HEARING, THIS
DAY, ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
ORAL ORDER
In this Petition, petitioner seeks the following reliefs:
"Wherefore, the Petitioner respectfully prays that this
Hon'ble High Court may be pleased to issue a writ, order
or direction:
i)Quashing the Notice under section 148 of the Act dated
30.03.2024 bearing DIN No. ITBA/AST/S/148_1/2023-
24/1063711145(1) (Annexure A) ISSUED by the 1
Respondent for the assessment year 2020-21;
ii) Quashing the Approval under section 151 of the Act
dated 30.03.2024 DIN bearing ITBA/AST/S/118/2023-
24/1063708075(1) No. (Annexure A1) issued by the 3rd
Respondent for the assessment year 2020-21;
iii) Quashing the Assessment Order under 147 read with
section 1448 of the Act dated 26.12.2024 bearing DIN
No.ITBA/AST/S/147/2024-25/1071599058(1) (Annexure
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C) passed by the 2nd Respondent for the assessment
year 2020-21;
iv) Quashing the Order u/s 270A of the Act dated
11.06.2025 bearing DIN No. ITBA/PNL/F/270A/2025-
26/1076926345(1) (Annexure D) issued by the 2nd
Respondent for the assessment year 2020-21;
v) Quashing the Notice of Demand under section 156 of
the Act dated bearing 11.06.2025
ITBA/PNL/S/156/2025-26/1076920674(1) DIN No.
(Annexure D1) issued by the 2nd Respondent for the
assessment year 2020-21;
vi) Pass such other orders as this Hon'ble Court deems fit
in the facts 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
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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 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
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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 -
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, C, D, and D1 dated 30.03.2024,
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30.03.2024, 26.12.2024, 11.06.2025 and
11.06.2025 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
BSV
