Karnataka High Court
Lakshmi Reddy Boyilla vs Assessment Unit on 19 November, 2025
Author: S.R.Krishna Kumar
Bench: S.R.Krishna Kumar
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NC: 2025:KHC:47819
WP No. 34735 of 2025
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 19TH DAY OF NOVEMBER, 2025
BEFORE
THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
WRIT PETITION NO. 34735 OF 2025 (T-IT)
BETWEEN:
LAKSHMI REDDY BOYILLA
SON OF SRI YANADI REDDY BOYILLA
AGED ABOUT 61 YEARS
PROP PRANAY ENTERPRISES 337-4
TIMMAREDDY LAYOUT HULIMANAGALA
POST JIGANI HOBLI ANEKAL
BANGALORE 560105
PAN AHUPB8646E
...PETITIONER
(BY SRI. ANNAMALAI S., ADVOCATE)
AND:
1. ASSESSMENT UNIT
INCOME TAX DEPARTMENT
Digitally signed REP BY ADDITIOBNAL /JOINT
by
SHARADAVANI DEPUTY /ASSISTANT COMMISSIONER
B OF INCOME TAX/INCOME TAX DEPARTMENT
Location: High
Court of MINISTRY OF FINANCE
Karnataka
ROOM NO.401 2ND FLOOR E-RAMP J
AWAHARALAL NEHARU STADIUM
DELHI- 110 003
2. THE INCOME TAX OFFICER
OFFICE OF THE INCOME TAX
OFFICER WARD 4(3) BANGALORE
BMTC BUILDING 80 FEET ROAD
6TH BLOCK NEAR KHB GAMES VILLAGE
KORMANAGALA BENGALURU
KARNATAKA 560095
...RESPONDENTS
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NC: 2025:KHC:47819
WP No. 34735 of 2025
HC-KAR
(BY SRI. E.I.SANMATHI., ADVOCATE)
THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF
THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE
SHOW-CAUSE NOTICE UNDER SECTION 144 OF THE ACT
DATED 08.12.2023 ISSUED BY THE RESPONDENT NO.1 FOR
THE ASSESSMENT YEAR 2019-20 BEARING DIN
ITBA/AST/F/144 (SCN) (F)/2023-24/1058602895(1) COPY OF
THE SAME IS REFERRED AS ANNEXURE A1QUASHING THE
SHOW-CAUSE NOTICEDATED 29.12.2023 ISSUED BY THE
RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2019-20
BEARING DIN NO. ITBA/AST/F/144(SCN)/2023-
24/1059181073(1) AND COPY OF THE SAME IS REFERRED AS
ANNEXURE A2
THIS PETITION, COMING ON FOR FINAL HEARING, THIS
DAY, ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
ORAL ORDER
In this petition, the petitioner seeks the following reliefs:
"Wherefore it is prayed that this Hon'ble Court be pleased to:
Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Show-cause notice under section 144 of the Act dated 08.12.2023 issued by the Respondent No.1 for the assessment year 2019-20 bearing DIN No. ITBA/AST/F/144(SCN)(F)/ 2023- 24/1058602895(1) and copy of the same is referred as Annexure-A1.-3-
NC: 2025:KHC:47819 WP No. 34735 of 2025 HC-KAR ii. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Show-cause notice dated 29.12.2023 issued by the Respondent No.1 for the assessment year 2019-20 bearing DIN No. ITBA/AST/F/144/(SNC)/2023-24/1059181073(1) and copy of the same is referred as Annexure 'A4'.
iii. Issue a writ of Certiorari or direction of certiorari quashing the Assessment order dated 06.02.2024 passed by the Respondent No.1 for the assessment year 2019-20 under section 147 read with section 144 read with section 144B of the Act bearing DIN No. ITBA/AST/S/147/2023- 24/1060531865(1) and copy of the same is referred as Annexure 'A3'.
iv. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Computation sheet dated 06.02.2024 issued by the Respondent No.1 for the assessment year 2019-20 bearing DIN & Document Number ITBA/AST/S/319/2023-24/1060532006(1) and copy of the same is referred as Annexure 'A4'.
v. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Demand notice 06.02.2024 Issued by the Respondent No.1 for the assessment year 2019-20 under section 156 of the Act bearing DIN NOTICE ITBA/AST/5/156/2023-24/1060531920(1) and copy of the same is referred as Annexure "A5.
-4-NC: 2025:KHC:47819 WP No. 34735 of 2025 HC-KAR vi. Issue a writ of Certiorari or direction in the nature of a wit of certiorari quashing Show cause notice dated 14-11-2023 Issued by the Respondent No.1 for the assessment year 2019-20 under section 274 read with section 272A(1)(d) of the Act bearing DIN No. ITBA/PNL/S/272A(1)(d)_FL/2023-24/1057923693(1) and copy of the same is referred as Annexure 'A6'.
vii. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Penalty order dated 27.05.2024 passed by the Respondent No.1 for the assessment year 2019-20 under section 272A(1)(d) of the Act bearing DIN No. ITBA/PNL/F/272A(1)(d)/2024- 25/1065155048(1) and copy of the same is referred as Annexure 'A7'.
viii. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Computation sheet dated 27.05.2024 issued by the Respondent No.1 for the assessment year 2019-20 bearing DIN & Order Number ITBA/PNL/S/272A(1)(d)_FL/2023-24/1057923693(1) copy of the same is referred as Annexure "A8".
ix. Issue a writ of Certiorari or direction in the nature of certiorari quashing the Demand notice date 27.05.2024 issued by the Respondent. No.1 for the assessment year 2019-20 under section 156 of the Act bearing DIN & -5- NC: 2025:KHC:47819 WP No. 34735 of 2025 HC-KAR Notice No. ITBA/PNL/S/156/2024-25/1065154915(1) and copy of the same is referred Annexure 'A9'.
x. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Show-cause notice dated 06.02.2024 Issued by the Respondent. No.1 for the assessment year 2019-20 under section 274 read with section 270A of the Act bearing DIN No. ITBA/PNL/S/270A/2023-24/1060531973(1) and copy of the same is referred as Annexure 'A10'.
xi. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Penalty order dated 22.08.2024 passed by the Respondent No.1 for the assessment year 2019-20 under section 272A(1)(d) of the Act bearing DIN No. ITBA/PNL/F/270A/2024- 25/1067971425(1) and copy of the same is referred as Annexure 'A11'.
xii. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Computation sheet dated 22.08.2024 issued by the Respondent No.1 for the assessment year 2019-20 bearing DIN & Order No. ITBA/PNL/S/270A/20234/1060531973(1) the same is referred as Annexure 'A12'.
xiii. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Demand notice dated -6- NC: 2025:KHC:47819 WP No. 34735 of 2025 HC-KAR 22.08.2024 issued by the Respondent No.1 for the assessment year 2019-20 under section 156 of the Act bearing DIN & Notice No. ITBA/PNL/S/156/2024- 25/1067970698(1) and copy of the same is referred as Annexure 'A13'.
xiv. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Show-cause notice dated 06.02.2024 issued by the Respondent No.1 for the assessment year 2019-20 under section 274 read with section 270A of the Act bearing DIN NO ITBA/PNL/S/27AC(1)/2023-24/1060531974(1) and copy of the same is referred as Annexure 'A14'.
xv. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Penalty order dated 23.08.2024 passed by the Respondent No.1 for the assessment year 2019-20 under Section - 271AAC(1) of the Act bearing DIN No.ITBA/PNL/F/271AAC(1)/202425/1067903863(1) and copy of the same is referred Annexure 'A15'.
xvi. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Computation sheet notice dated 23.08.2024 issued by the Respondent No.1 for the assessment year 2019-20 bearing DIN & Order No. ITBA/PNL/S/156/271AAC(1)/2023-25/1060531974(1) and copy of the same is referred as Annexure A16.
-7-NC: 2025:KHC:47819 WP No. 34735 of 2025 HC-KAR xvii. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Demand notice dated 23.08.2024 issued by the Respondent No.1 for the assessment year 2019-20 under Section - 156 of the Act bearing DIN & Notice No. ITBA/PNL/S/156/2024- 25/1067898592(1) and copy of the same is referred as Annexure A17.
xviii. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Notice issued under section 148A(b) of the Act dated 13.02.2023 issued by the Respondent No. 2 for the assessment year 2019-20 bearing DIN & Notice No. ITBA/AST/F/148A(SCN)/2022- 23/1049715990(1) and copy of the same is referred as Annexure 'B1'.
xix. Issue a writ of Certiorari or direction in the nature of writ of certiorari quashing the Notice issued under section 1484(d) of the Act dated 27.02.2023 issued by the Respondent No.2 for the assessment year 2019-20 bearing DIN No.ITBA/AST/F/148A(SCN)/ 202223/1050177116(1) and copy of the same is referred Annexure 'B2".
xx. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Order passed under section 148A(d) of the Act dated 10.03.2023 by the -8- NC: 2025:KHC:47819 WP No. 34735 of 2025 HC-KAR Respondent No.2 for the assessment year 2019-20 bearing DIN No ITBA/AST/F/148A/2022- 23/1050613914(1) and copy of the same is referred as Annexure 'B3".
xxi. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Notice issued under section 148 of the Act dated 11.03.2023 bearing DIN & Notice No. ITBA/AST/S/148_1/202223/1050647542(1) issued by the Respondent No.2 for the assessment year 2019-20 and copy of the same is referred as Annexure 'B4'.
xxii. 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 the petitioner and learned counsel for the respondents and perused the material on record.
3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitioner invited my attention to the order of a Co-
ordinate Bench of this Court in the case of Ramachandra -9- NC: 2025:KHC:47819 WP No. 34735 of 2025 HC-KAR Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order.
4. Per contra, learned counsel for the respondents submits that there is no merit in the petition and that the same is liable to be dismissed.
5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax -
W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under:
"13. I, therefore, pass the following:
ORDER
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NC: 2025:KHC:47819 WP No. 34735 of 2025 HC-KAR
(i) The impugned show cause notices issued by the jurisdictional Assessing Officer outside the scope of Section 151-A of the Act stand obliterated. All further proceedings initiated thereto, challenged in these cases would stand quashed.
(ii) Liberty is reserved to the respondents -
revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it.
(iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed.
(iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of these petitions would become necessary."
6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of co-ordinate Bench of this Court in Ramachandra Reddy's case (supra).
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NC: 2025:KHC:47819 WP No. 34735 of 2025 HC-KAR
7. In the result, I pass the following:
ORDER
(i) The petition is allowed and disposed of in terms of the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax -
W.P.No.17352/2022 and connected matters
- dated 28.08.2025.
(ii) The impugned show cause notices and consequential orders, notices etc., at Annexures- A1 to B4 dated 08.12.2023, 29.12.2023, 06.02.2024, 06.02.2024, 06.02.2024, 14.11.2023, 27.05.2024, 27.05.2024, 27.05.2024, 06.02.2024, 22.08.2024, 22.08.2024, 06.02.2024, 06.02.2024, 23.08.2024, 23.08.2024, 23.08.2024, 13.02.2023, 27.02.2023, 10.03.2023, 11.03.2023, respectively are hereby quashed.
(iii) Liberty is reserved in favour of the respondents
- Revenue to seek revival of this petition, subsequent to disposal of the matters pending before the Apex Court and all rival contentions
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NC: 2025:KHC:47819 WP No. 34735 of 2025 HC-KAR between the parties in this regard are kept open and no opinion is expressed on the same.
Sd/-
(S.R.KRISHNA KUMAR) JUDGE JJ List No.: 3 Sl No.: 14