IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24^TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 17675 OF 2021 (T-IT)

BETWEEN:

SINGAYANAPALYA ANJINAPPA PUTTARAJU S/O SRI P. ANJINAPPA, AGED 58 YEARS, NO.12, SAVIRAJ MANSION, MAHESHWARI NAGAR, MAHADEVAPURA, BENGLAURU – 560 048 …PETITIONER (BY SRI. A. SHANKAR, SENIOR COUNSEL FOR SRI. ANNAMALAI S., ADVOCATE)

AND:

1. NATIONAL FACELESS ASSESSMENT CENTRE REP. BY ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME-TAX/INCOME-TAX OFFICER, INCOME-TAX DEPARTMENT, Di gitally MINISTRY OF FINANCE, signed by ROOM NO.401, 2^ND FLOOR, E-RAMP MADHURI S JAWARHALAL NEHRU STADIUM Location : DELHI – 110 003 High Court of Karnataka

2. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(1)(1), BMTC BUILDING, 80 FEET ROAD, 6^TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU – 560 095 …RESPONDENTS (BY SRI. RAVI RAJ Y. V., & SRI. M. DILIP, ADVOCATES)

THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ASSESSMENT ORDER PASSED BY THE R1 U/S 14393) R/W SECTION 144B OF THE INCOME-TAX ACT, 1961 DATED 09.08.2021 FOR THE ASSESSMENT YEAR 2018-19 HEREIN MARKED AS ANNEXURE-A1 AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR

ORAL ORDER

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

“i) Issue a writ of Certiorari and direction in the nature of a writ of certiorari quashing the assessment order passed by the Respondent No.1 under section 143(3) read with section 144B of the Income-tax Act, 1961 dated 09.08.2021 for the assessment year 2018-19 herein marked as Annexure-A1.

ii) Issue a writ of Certiorari and direction in the nature of a writ of certiorari quashing the Computation sheet passed by the Respondent No.1 for the assessment order passed under section 143(3) read with section 144B of the Income-tax Act, 1961 dated 09.08.2021 for the assessment year 2018-19 herein marked as Annexure-A2.

iii) Issue a writ of Certiorari and direction in the nature of a writ of certiorari quashing the Notice of demand issued under section 156 of the Income-tax Act, 1961 dated 09.08.2021 for the assessment year 2018-19 for a sum of Rs.21,70,81,315/- herein marked as Annexure-A3.

iv) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.

2. Heard learned counsel for both parties and perused the material on record.

3. A perusal of the material on record will indicate that on

23.04.2021 respondent No.1 issued show-cause notice along with draft Assessment Order calling upon the petitioner to submit reply/response on or before 26.04.2021, i.e., within three days and lesser than the stipulated period of seven days as per the Standard Operating Procedure (SOP). Though the petitioner submitted a reply to the said show-cause notice, the respondents issued one more notice dated 07.08.2021 and without providing an opportunity to the petitioner to submit reply, proceeded to pass the impugned order, which is assailed in the present petition.

4. In the case of Bangalore Metro Rail Corporation Limited Vs. Assessment Unit, Income Tax Department and another - W.P.No.33047/2025 dated 03.11.2025, in relation to non-compliance of the period of seven days as per the SOP, this Court held as under:

In this petition, the petitioner seeks the following reliefs:

" i. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the show cause notice dated 15.01.2025 issued by the Respondent No.1 for the assessment year 2023-24 DIN bearing ITBA/AST/F/144(SCN)/2024-25/1072178455(1) herein marked as Annexure 'A'.

ii. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the assessment order dated 06.03.2025 passed by the Respondent No. 1 under Section 144 read with Section 144B of Act for the assessment year 2023-24 bearing DIN No. ITBA/AST/S/