IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24^TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 23544 OF 2024 (T-IT)

BETWEEN:

DILEEP KUMAR KRISHNA MURTHY, S/O N.KRISHNA MURTHY, AGED ABOUT 51 YEARS, NO. 135/2, N M ROAD, PANDAVAPURA, MANDYA – 571 434.

…PETITIONER (BY SMT. LOCHANA S. BABU, ADVOCATE)

AND:

1. THE INCOME TAX OFFICER, WARD-1 AND TPS, MANDYA, INCOME TAX OFFICE, Digitally signed by NAGAVENI CAUVERY PARK ROAD, Location:

HIGH COU RT MANDYA – 571 401.

OF KARNATAKA

2. THE PRINCIPAL COMMISSIONER OF INCOME TAX-3, BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6^TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095. 3. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO 401, 2^ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI – 110 003.

…RESPONDENTS (BY SRI M.THIRUMALESH, ADVOCATE)

THIS WRIT PETITION IS FILED UNDER ARTICLES 226 &

227 OF THE CONSTITUTION OF INDIA PRAYING TO PRAYING TO A) QUASHING THE NOTICE ISSUED UNDER SECTION 148A(b) OF THE ACT DATED 08.02.2023 OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2022- 23/1049525988(1) HEREIN MARKED AS ANNEXURE – A; B) QUASHING THE UNSIGNED SANCTION DATED 07.03.2023 PASSED UNDER SECTION 151 OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.2 BEARING DIN AND NOTICE NO.ITBA/AST/S/118/2022- 23/1050477562(1) HEREIN MARKED AS ANNEXURE - A1; C) QUASHING THE ORDER DATED 07.03.2023 PASSED UNDER SECTION 148A(d) OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.1 BEARING DIN AND NOTICE NO.ITBA/AST/F/148A/2022-23/1050479748(1) HEREIN MARKED AS ANNEXURE A2; D) QUASHING THE NOTICE DATED 07.03.2023 ISSUED UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.1 BEARING DIN AND NOTICE NO. ITBA/AST/S/148_1/2022-23/1050480337(1) HEREIN MARKED AS ANNEXURE-A3; E) QUASHING THE ORDER DATED 15.02.2024 PASSED UNDER SECTION 147 R.W.S 144 R.W.S 144B OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.3 BEARING DIN AND NOTICE NO. ITBA/AST/S/147/2023-24/1060992375(1) HEREIN MARKED AS ANNEXURE A4; F) QUASHING THE COMPUTATION SHEET DATED 15.02.2024 ISSUED FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.3 BEARING DIN AND NOTICE NO. ITBA/AST/S/319/2023-24/1060992539(1) HEREIN MARKED AS ANNEXURE - A5; XVI) QUASHING THE DEMAND NOTICE DATED 15.02.2024 ISSUED UNDER SECTION 156 OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.3 BEARING DIN & NOTICE NO. ITBA/AST/S/156/2023-24/1060992523(1) HEREIN MARKED AS ANNEXURE - A6; XVII) QUASHING THE PENALTY SHOW CAUSE NOTICE DATED 15.02.2024 ISSUED UNDER SECTION 271AAC(1) OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.3 BEARING DIN AND NOTICE NO. ITBA/PNL/S/271AAC(1)/2023-24/1060992643(1) HEREIN MARKED AS ANNEXURE - A7; XVIII) QUASHING THE PENALTY ORDER DATED 15.08.2024 PASSED UNDER SECTION 271AAC(1) OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.3 BEARING DIN AND NOTICE NO. ITBA/PNL/F/271AAC(1)/2024-25/1067663007(1) HEREIN MARKED AS ANNEXURE - A8; XIX) QUASHING THE PENALTY SHOW CAUSE NOTICE DATED 15.02.2024 ISSUED UNDER SECTION 271B OF THE ACT FOR THE ASSESSMENT YEAR 2019- 20 BY THE RESPONDENT NO.3 BEARING DIN AND NOTICE ITBA/PNL/S/271B/2023-24/1060992656(1) HEREIN MARKED AS ANNEXURE - A9; XX) QUASHING THE PENALTY ORDER DATED 05.08.2024 PASSED UNDER SECTION 271B OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.3 BEARING DIN AND NOTICE NO. ITBA/PNL/F/271B/2024- 25/1067333284(1) HEREIN MARKED AS ANNEXURE A10; XXI) QUASHING THE PENALTY SHOW CAUSE NOTICE DATED 15.02.2024 ISSUED UNDER SECTION 272A(1)(d) OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.3 BEARING DIN AND NOTICE NO. ITBA/PNL/S/272A(1)(d)_FL/2023-24/1060991573(1) HEREIN MARKED AS ANNEXURE - A11; XXII) QUASHING THE PENALTY ORDER DATED 05.08.2024 PASSED UNDER SECTION 272A(1)(d) OF THE ACT FOR THE ASSESSMEN