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. 4845 OF 2025 (T-IT)

BETWEEN:

PRATHAMIKA KRUSHI PATHINA SAHAKARA SANGHA NIYAMITHA YADAGANAHALLI PAN: AAEAP5273B PRESENTLY KNOWN AS VIVIDHODHESHA PRARTHAMIKA GRAMINA KRUSHI SAHAKARA SANGHA NIYAMITHA YADAGANAHALLI.

CHIKKARASINAKERE HOBLI, MADDUR, MANDYA-571422 PREVIOUSLY KNOWN AS VYAVASAYA SEVA SHAHAKARI BANK NIYAMITHA PAN: AAAAV0708K.

REPRESENTED BY, Digitally signed PRAVEEN KUMAR Y T, by NAGAVENI CEO OF THE PETITIONER, AGED 29 YEARS, Location: High Court of S/O THIMEGOWDA YADAGANAHALLI THIMMEGOWDA, Karnataka GOVERNMENT HOSPITAL ROAD, YADAGANAHALLY, CHIKKA ARASINAKERE HOBALI, MADDUR TALUK, MANDYA-571422.

…PETITIONER (BY SRI. RAVI SHANKAR S. V., ADVOCATE)

AND:

1. INCOME TAX OFFICER WARD 1 AND TPS, MANDYA-571401.

2. NATIONAL FACELESS ASSESSMENT CENTRE, ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/

INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2^ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110003.

3. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3, THE OFFICE OF THE PRINCIPAL COMMISSIONER OF INCOME TAX - 3, BMTC BUILDING, KORAMANGALA, BANGALORE 560095 …RESPONDENTS (BY SRI. M. THIRUMALESH, ADVOCATE FOR R1 TO R3.)

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. 20.03.2022 DIGITALLY SIGNED ON 21.03.2022 BEARING DIN NO. ITBA/AST/F/148A(SCN)/2021-22/1041109230(1) ISSUED BY THE R-1 FOR THE ASSESSMENT YEAR 2018-19 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 20/03/2022, digitally signed on 21.03.2022 bearing DIN No.

ITBA/AST/F/148A(SCN)/2021-22/1041109230(1), issued by Respondent No.1 for the Assessment year

2018-19 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 25/04/2022 bearing DIN No. ITBA/AST/F/148A/2022- 23/1042844836(1) passed by Respondent No.1 for the Assessment year 2018-19 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 26/04/2022, bearing DIN No. ITBA/AST/S/148_1/2022- 23/1042852756(1), issued by Respondent No.1 for the Assessment year 2018-19 herein marked as Annexure - A2.

iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed under Section 147 r.w.s. 144, 144B of the Act, dated 14/12/2023 bearing DIN No.ITBA/AST/S/147/2023-24/1058769711(1)

issued by Respondent No.2 for the Assessment year

2018-19 herein marked as Annexure - A3.

v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty order under Section 272A(1)(d) of the Act, dated 25/06/2024 bearing DIN No.

ITBA/PNL/F/272A(1)(D)/2024-25/1066042823(1)

by Respondent No.2 for the Assessment year 2018-

19 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 271AAC(1) of the Act, dated 26/06/2024, bearing DIN No.

ITBA/PNL/F/271AAC(1)/2024-25/1066058929(1)

by Respondent No.2 for the Assessment year 2018-

19 herein marked as Annexure - A5.

vii) 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, learned counsel appearing for petitioner and Sri M. Thirumalesh, learned counsel appearing for respondents 1 to 3.

3. The issue revolves around the minimum per