Karnataka High Court
Mr Praveen Kumar vs Union Of India on 29 October, 2025
Author: S.R.Krishna Kumar
Bench: S.R.Krishna Kumar
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NC: 2025:KHC:43297
WP No. 32445 of 2025
HC-KAR
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. 32445 OF 2025 (T-IT)
BETWEEN:
1. MR. PRAVEEN KUMAR
PROPRIETOR,
AGED ABOUT 46 YEARS
M/S. ARIHANT STEEL
HAVING OFFICE AT NO.222/6,
K.H. RANGANATHA COLONY,
OPP. BHEL, MYSORE ROAD,
BENGALURU - 560 039.
...PETITIONER
(BY SRI. BHARATH KUMAR V., ADVOCATE)
AND:
1. UNION OF INDIA
Digitally signed THROUGH PRINCIPAL SECRETARY,
by
SHARADAVANI MINISTRY OF FINANCE,
B
Location: High DEPARTMENT OF REVENUE
Court of ROOM NO.66-A, NORTH BLOCK
Karnataka
NEW DELHI - 110 001
2. ASSISTANT COMMISSIONER OF INCOME TAX,
CENTRAL CIRCLE - 2(4) BLR,
HAVING OFFICE AT
CENTRAL REVENUE BUILDING,
QUEENS ROAD,
BENGALURU - 560 001.
...RESPONDENTS
(BY SRI. M. DILIP, ADVOCATE FOR R1 AND R2)
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WP No. 32445 of 2025
HC-KAR
THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF
THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE
NOTICE DATED 06.12.2022 BEARING DIN AND NOTICE NO.
ITBA/AST/F/148A (SCN)/2022-23/1047818813(1) ISSUED BY
THE RESPONDENT NO. 2 UNDER SECTION 148A(B) OF THE
INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2020-21
(ANNEXURE A).
THIS PETITION, COMING ON FOR PRELIMINARY
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, it is prayed that this Hon'ble Court may be
pleased to:
a. Issue a writ order of direction in the nature of certiorari
or any other appropriate writ quashing the notice dated
06.12.2022 bearing DIN & Notice No. ITBA/AST/F/148A
(SCN)/2022-23/1047818813(1) issued by the Respondent
No. 2 under Section 148A(b) of the Income Tax Act, 1961
for the Assessment Year 2020-21 (Annexure A);
b. Issue a writ order of direction in the nature of certiorari
or any other appropriate writ quashing the notice dated
25.01.2023 bearing DIN & Notice No. ITBA/AST/F/148A
(SCN)/2022-23/1049094210(1) issued by the Respondent
No. 2 under Section 148A(b) of the Income Tax Act, 1961
for the Assessment Year 2020-21 (Annexure A1);
c. Issue a writ order of direction in the nature of certiorari
or any other appropriate writ quashing the notice dated
31.01.2023 bearing DIN & Notice No. ITBA/AST/F/148A
(SCN)/2022-23/1049283013(1) issued by the Respondent
No. 2 under Section 148A(b) of the Income Tax Act, 1961
for the Assessment Year 2020-21 (Annexure A2);
d. Issue a writ, order of direction in the nature of
certiorari or any other appropriate writ quashing the
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notice dated 17.03.2023 bearing DIN & Notice No.
ITBA/AST/S/148_1/2022-23/1050879921(1) issued by
the Respondent No. 2 under Section 148 of the Income
Tax Act, 1961 for the Assessment Year 2020-21
(Annexure B).
e. Grant such other relief that this Hon'ble Court may
deem fit in the facts of the present matter."
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.
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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
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.
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(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, A2, B dated 06.12.2022, 25.01.2023,
31.01.2023 and 17.03.2023 respectively are
hereby quashed.
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(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
CT-SG
