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2025 DIGILAW 1692 (KAR)

Palakshi Hanumanthappa Harthi S/o Shri Hanumanthappa v. Income Tax Officer, Ayakar Karyalaya

2025-12-08

M.NAGAPRASANNA

body2025
ORDER : 1. The petitioner - Assessee in W.P. No.107106 of 2024 is before this Court seeking quashment of the unsigned sanction dated 30.03.2024 accorded under Section 151 of the Act for the AY-2020-21 by respondent No.2 vide Annexure-A and notice dated 30.03.2024 issued under Section 148 of the Act for the AY-2020-21 by respondent No.1 vide Annexure-A1; 1.1. The petitioner - Assessee in W.P. No.107107 of 2024 is before this Court seeking quashment of the notice dated 09.08.2024 issued under Section148A(b) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A, unsigned sanction dated 29.08.2024 accorded under Section 151 of the Act for the AY-2018-19 by respondent No.2 vide Annexure-A1, order dated 29.08.2024 issued under Section 148A(d) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A2, notice dated 29.08.2024 issued under Section 148 of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A3; 1.2. The petitioner - Assessee in W.P. No.107108 of 2024 is before this Court seeking quashment of the notice dated 07.08.2024 issued under Section148A(b) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A, unsigned sanction dated 28.08.2024 accorded under Section 151 of the Act for the AY-2018-19 by respondent No.2 vide Annexure-A1, order dated 29.08.2024 issued under Section 148A(d) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A2, notice dated 29.08.2024 issued under Section 148 of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A3; 1.3. The petitioner - Assessee in W.P. No.107122 of 2024 is before this Court seeking quashment of the notice dated 07.08.2024 issued under Section148A(b) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A, unsigned sanction dated 28.08.2024 accorded under Section 151 of the Act for the AY-2018-19 by respondent No.2 vide Annexure-A1, order dated 29.08.2024 issued under Section 148A(d) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A2, notice dated 29.08.2024 issued under Section 148 of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A3; 1.4. The petitioner - Assessee in W.P. No.107123 of 2024 is before this Court seeking quashment of the notice dated 07.08.2024 issued under Section148A(b) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A, unsigned sanction dated 28.08.2024 accorded under Section 151 of the Act for the AY-2018-19 by respondent No.2 vide Annexure-A1, order dated 29.08.2024 issued under Section 148A(d) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A2, notice dated 29.08.2024 issued under Section 148 of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A3; 1.5. The petitioner - Assessee in W.P. No.107124 of 2024 is before this Court seeking quashment of the notice dated 07.08.2024 issued under Section148A(b) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A, unsigned sanction dated 27.08.2024 accorded under Section 151 of the Act for the AY-2018-19 by respondent No.2 vide Annexure-A1, order dated 27.08.2024 issued under Section 148A(d) of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A2, notice dated 27.08.2024 issued under Section 148 of the Act for the AY-2018-19 by respondent No.1 vide Annexure-A3. 2. Heard Sri Hemanth Pai, Sri Lochana S.Babu & Shashank S.Hegde, learned counsels appearing for the petitioner and Sri Thirumalesh & Smt Roopa, learned counsels representing the respondents in all these petitions. 3. The grounds projected in the subject petitions in support of the prayer quoted supra are identical to the ones considered by this Court in W.P.No.28182/2024 and connected matters, disposed on 28.08.2025. 4. In the light of the issue being similar and the reasons rendered therein becomes applicable to the cases at hand, the petitions deserve to be disposed on the same lines. Therefore, I pass the following: ORDER: (i) The unsigned sanction dated 30.03.2024 vide Annexure-A and notice dated 30.03.2024 vide Annexure-A1, for the AY-2020-21 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107106 of 2024 stand quashed. (ii) The notice dated 09.08.2024 vide Annexure-A, unsigned sanction dated 29.08.2024 vide Annexure-A1, order dated 29.08.2024 vide Anneuxre-A2, notice dated 29.08.2024 vide Annexure-A3, for the AY-2018-19 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107107 of 2024 stand quashed. (ii) The notice dated 09.08.2024 vide Annexure-A, unsigned sanction dated 29.08.2024 vide Annexure-A1, order dated 29.08.2024 vide Anneuxre-A2, notice dated 29.08.2024 vide Annexure-A3, for the AY-2018-19 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107107 of 2024 stand quashed. (iii) The notice dated 07.08.2024 vide Annexure-A, unsigned sanction dated 28.08.2024 vide Annexure-A1, order dated 29.08.2024 vide Anneuxre-A2, notice dated 29.08.2024 vide Annexure-A3, for the AY-2018-19 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107108 of 2024 stand quashed. (iv) The notice dated 07.08.2024 vide Annexure-A, unsigned sanction dated 28.08.2024 vide Annexure-A1, order dated 29.08.2024 vide Anneuxre-A2, notice dated 29.08.2024 vide Annexure-A3, for the AY-2018-19 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107122 of 2024 stand quashed. (v) The notice dated 07.08.2024 vide Annexure-A, unsigned sanction dated 28.08.2024 vide Annexure-A1, order dated 29.08.2024 vide Anneuxre-A2, notice dated 29.08.2024 vide Annexure-A3, for the AY-2018-19 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107123 of 2024 stand quashed. (vi) The notice dated 07.08.2024 vide Annexure-A, unsigned sanction dated 27.08.2024 vide Annexure-A1, order dated 27.08.2024 vide Anneuxre-A2, notice dated 27.08.2024 vide Annexure-A3, for the AY-2018-19 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in W.P. No.107124 of 2024 stand quashed. (vii) Liberty is reserved to the respondents-revenue to revive the petitions in the event, the Apex Court would hold in favour of the Revenue in the matter pending before it. (viii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. (ix) 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.