IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 29^TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 27081 OF 2023 (T-IT)

BETWEEN:

KANGADAN MAJEED S/O SRI ABDULLA AGED ABOUT 45 YEARS RESIDENT AT SY NO 87 INDIRA LAYOUT BICHANAHALLY KUSHALNAGAR KODAGU 571234 PAN ARJPM2316F …PETITIONER (BY SRI. ANNAMALAI S., ADVOCATE)

AND:

1. THE ASSESSMENT UNIT NATIONAL FACELESS ASSESSMWENT CENTRE REP. BY ADDL/JOINT/DEPUTY / ASSISTANT COMMISSONER Digitally signed OF INCOME TAX by CHANDANA INCOME TAX OFFICER, B M INCOME TAX DEPARTMENT, Location: High MINISTRY OF FINANCE, Court of Karnataka ROOM O 401, 2^ND FLOOR, E RAMP JAWARHARLAL NEHRU STADIUM DELHI – 110 003

2. THEINCOME TAX OFFICER WARD MADIKERI MADIKERI - SRIVALLI BUILDING MADIKERI MYSURU – 571 201 …RESPONDENTS (BY SRI. SUSHAL TIWARI, ADVOCATE)

THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ASSESSMENT ORDER PASSED BY THE R1 UNDER SECTION 147 RWS 144 RWS 144B OF THE INCOME TAX ACT, 1961 DATED 21/03/2023 BEARING DIN NO. ITBA/AST/S/147/2022-23/1051051105(1) 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 or direction in the nature of a writ of certiorari quashing the assessment order passed by the Respondent No.1 under section 147 rws 144 rws 144B of the Income Tax Act, 1961 dated 21/03/2023 bearing DIN No. ITBA/AST/S/147/2022- 23/1051051105(1) for the assessment year 2018-19 herein marked as Annexure-A1.

(ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet issued by the Respondent No.1 dated 21.03.2023 bearing DIN and Document No: ITBA/AST/S/183/2022-23/1051051210(1) in respect of the assessment year 2018-19 herein marked as Annexure-A2.

iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand issued under section 156 of the Act by the Respondent No.1 dated 21.03.2023 bearing DIN and Notice No: ITBA/AST/S/156/2022-23/1051051195(1) in respect of the assessment year 2018-19 herein marked as Annexure-A3.

iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order passed under section 271AAC(1) of the Act by the Respondent No.1 dated 21/09/2023 bearing DIN No. ITBA/PNL/F/271AAC(1)/2023-24/1056344727(1) in respect of assessment year 2018-19 herein marked as Annexure-A4.

v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet issued by the Respondent No.1 dated 21.09.2023 bearing DIN and Document No: ITBA/PNL/S/271AAC(1)/2022-23/1051051206 (1) in respect of the assessment year 2018-19 herein marked as Annexure-A5.

vi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand issued under section 156 of the Act by the Respondent No.1 dated 21.09.2023 bearing DIN and Notice No: ITBA/PNL/S/156/2023-24/1056344696(1) in respect of the assessment year 2018-19 herein marked as Annexure-A6.

vii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order passed under section 270A of the Act by the Respondent No.1 dated 25/09/2023 bearing DIN No. ITBA/PNL/F/270A/2023-24/1056534369(1) in respect of assessment year 2018-19 herein marked as Annexure-A7.

viii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet issued by the Respondent No.1 dated 25.09.2023 bearing DIN and Document No: ITBA/PNL/S/270A/2022-23/1051051205(1) in respect of the assessment year 2018-19 herein marked as Annexure-A8.

ix) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notic