IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18^TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 2653 OF 2025 (T-IT)

BETWEEN:

LATE SURENDRA BABU PAGADALA BHOJARAJULU NAIDU, 6, PAGADALA A CASTLE, MIDDLE SCHOOL ROAD, V V PURAM, BANGALORE - 560004.

PAN: AALHS0881E

1. REP. BY LEGAL HEIR AND KARTA, SRI. P S BHUVANESVAR, AGED 33 YEARS, S/O LATE SURENDRA BABU PAGADALA BHOJARAJULU NAIDU, 201, 3^RD MAIN, 4^TH B CROSS, OMBR LAYOUT, BANASWADI, KALYANANAGAR S.O., BANGALORE - 560043.

Digitally signed by NAGAVENI …PETITIONER Location: H igh (BY SRI. RAVI SHANKAR S. V., ADVOCATE)

Court of Karnataka AND:

1. INCOME TAX OFFICER WARD 5(2)(1), BANGALORE-560095.

2. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX THE OFFICE OF THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, C R BUILDING, BANGALORE - 560001.

…RESPONDENTS (BY SRI. M. THIRUMALESH, ADVOCATE FOR R1 AND R2.) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE UNDER SECTION 148A(b) OF THE ACT, DTD. 21.03.2022 BEARING DIN NO. ITBA/AST/F/148A(SCN)/2021-22/1041178077(1) ISSUED BY THE R-1 FOR THE ASSESSMENT YEAR 2015-16 HEREIN MARKED AS ANNX-A AND ETC.

THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA

ORAL ORDER

The petitioner is before this Court seeking the following prayers:

“i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148A(b) of the Act, dated 21/03/2022, bearing DIN No.ITBA/AST/F/148A(SCN)/2021- 22/1041178077(1), issued by Respondent No.1 for the Assessment year 2015-16 herein marked as Annexure-A.

ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order under Section 148A(d) of the Act dated 30/03/2022 bearing DIN No. ITBA/AST/F/148A/2021- 22/1042178394(1) passed by Respondent No.1 for the Assessment year 2015-16 herein marked as Annexure - A1.

iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148 of the Act, dated 31/03/2022, bearing DIN No. ITBA/AST/S/148_1/2021- 22/1042245168(1), issued by Respondent No.1 for the Assessment year 2015-16 herein marked as Annexure - A2.

iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the assessment order under Section 147 r.w.s. 144 of the Act, dated 27/03/2023, bearing DIN No.ITBA/AST/S/147/2022-23/1051367471(1)

passed by Respondent No.1 for the Assessment year 2015-16 herein marked as Annexure - A3.

v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the rectification order under Section 154 r.w.s 147 of the Act, dated 23/09/2023 bearing DIN No.

ITBA/REC/S/154_1/2023-24/1056456464(1)

passed by Respondent No.1 for the Assessment year 2015-16 herein marked as Annexure - A4.

vi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order under Section 271(1)(b) of the Act, dated 27/09/2023, bearing DIN No.

ITBA/PNL/F/271(1)(b)/2023-24/1056607952(1)

passed by Respondent No.1 for the Assessment year 2015-16 herein marked as Annexure - A5.

vii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order under Section 271(1)(c) of the Act, dated 27/09/2023, bearing DIN No.

ITBA/PNL/F/271(1)(c)/2023-24/1056597717(1)

passed by Respondent No.1 for the Assessment year 2015-16 herein marked as Annexure - A6.

viii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order under Section 271F of the Act, dated 27/09/2023, bearing DIN No. ITBA/PNL/F/271F/2023- 24/1056615058(1) passed by Respondent No.1 for the Assessment year 2015-16 herein marked as Annexure - A7.

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

2. Heard Sri Ravi Shankar S V, le