SETHURAMAN KARNAN, vs. ASSESSMENT UNIT,

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WP/24890/2026HC KarnatakaKAHC01055082202618 August 2026Bench: B M SHYAM PRASAD4 pages
AI SummaryWithdrawn

What did the High Court hold?

The petitioner, through their counsel, filed a memo requesting permission to withdraw the writ petition with liberty to file a fresh writ petition if circumstances warrant. The High Court, after hearing the counsel, allowed the withdrawal. The petition was disposed of without prejudice to the petitioner's right to prosecute an appeal as permissible in law. No decision was made on the merits of the issues raised in the writ petition.

What were the facts?

The petitioner, Sethuraman Karnan, filed a writ petition before the High Court of Karnataka challenging several notices and orders issued by the Assessment Unit (R1) under the Income Tax Act, 1961, for the Assessment Year 2024-25. These included a notice under Section 143(2), an assessment order under Section 143(3) read with Section 144B, a notice of demand under Section 156, a communication sheet, a notice for penalty under Section 274 read with Section 270A, and a notice for penalty under Section 274 read with Section 271AAC(1). The respondents included various faceless assessment authorities and the jurisdictional Assessing Officer.

What were the issues?

1. Whether the digitally signed and electronically communicated notice under Section 143(2) of the Income Tax Act, 1961, dated 23/06/2025, issued by R1 for the Assessment Year 2024-25, is liable to be quashed? 2. Whether the digitally signed and electronically communicated assessment order under Section 143(3) read with Section 144B of the Income Tax Act, 1961, dated 04/02/2026, issued by R1 for the Assessment Year 2024-25, is liable to be quashed? 3. Whether the digitally signed and electronically communicated notice of demand under Section 156 of the Income Tax Act, 1961, dated 04/02/2026, issued by R1 for the Assessment Year 2024-25, is liable to be quashed? 4. Whether the digitally signed and electronically communicated communication sheet dated 04/02/2026, issued by R1 for the Assessment Year 2024-25, is liable to be quashed? 5. Whether the digitally signed and electronically communicated notice for penalty under Section 274 read with Section 270A of the Income Tax Act, 1961, dated 04/02/2026, issued by R1 for the Assessment Year 2024-25, is liable to be quashed? 6. Whether the digitally signed and electronically communicated notice for penalty under Section 274 read with Section 271AAC(1) of the Income Tax Act, 1961, dated 04/02/2026, issued by R1 for the Assessment Year 2024-25, is liable to be quashed? The petitioner sought to quash these notices and orders. The judgment does not record specific arguments from the revenue. The petitioner's counsel filed a memo for withdrawal.

Which sections of the Income-tax Act were involved?

Section 143(2),Section 143(3),Section 144B,Section 156,Section 270A,Section 271AAC(1),Section 274

AI-generated summary — verify with the full judgment below

HC-KAR IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18TH DAY OF AUGUST, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 24890 OF 2026 (T-IT) BETWEEN:

SETHURAMAN KARNAN, SON OF SRI SETHURAMAN, AGED ABOUT 56 YEARS, NO. 2/6, 6TH CROSS, BEHIND MINARVA MILL, MAGADI ROAD, BENGALURU 560023 …PETITIONER (BY SRI. SHREEHARI KUTSA.,ADVOCATE) AND:

1.

ASSESSMENT UNIT, A UNIT CREATED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI 110 003 REP. BY PR. COMMISSIONER OF INCOME TAX (NEAC)

2.

NATIONAL FACELESS ASSESSMENT CENTRE (NAFAC), A CENTRE DESCRIBED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961 ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM,

Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA HC-KAR DELHI 110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC)

3.

INCOME TAX OFFICER, WARD 5(1)(1), BENGALURU, THE JURISDICTIONAL ASSESSING OFFICER, UNDER THE INCOME TAX ACT, 1961, BMTC BUILDING, 2ND FLOOR, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BENGALURU 560095

4.

PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-5, AN AUTHORITY UNDER SECTION 116 OF THE INCOME TAX ACT, 1961, BMTC BUILDING, 2ND FLOOR, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BENGALURU 560095 …RESPONDENTS

(BY SRI. M. THIRUMALESH, ADVOCATE A/W SRI. NIRMAL MATHEW, ADVOCATE)

THIS WP IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING QUASHING OF THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED NOTICE UNDER SECTION 143(2) OF THE INCOME TAX ACT, 1961, DATED 23/06/2025 ISSUED BY R1 FOR THE ASSESSMENT YEAR 2024-25 WHICH BEARS THE DIN VIZ., ITBA/AST/S/143(2)/2025- 26/1077552357(1) AND ENCLOSED AS ANNEXURE B. B) QUASHING OF THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED ASSESSMENT ORDER UNDER SECTION 143(3) R.W.S. 144B OF THE INCOME TAX ACT, 1961, DATED 04/02/2026 ISSUED BY R1 FOR THE ASSESSMENT YEAR 2024-25 WHICH HC-KAR BEARS THE DIN VIZ ITBA/AST/S/143(3)/2025- 26/1085557741(1) ENCLOSED AS ANNEXURE K1. C) QUASHING OF THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED NOTICE OF DEMAND UNDER SECTION 156 OF THE INCOME TAX ACT, 1961, DATED 04/02/2026 ISSUED BY R1 FOR THE ASSESSMENT YEAR 2024-25 WHICH BEARS THE DIN VIZ ITBA/AST/S/156/2025-26/1085557841(1) AND ENCLOSED AS ANNEXURE K2. D) QUASHING OF THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED COMMUNICATION SHEET DATED 04/02/2026 ISSUED BY R1 FOR THE ASSESSMENT YEAR 2024-25 WHICH BEARS THE DIN AND DOCUMENT NO. ITBA/AST/S/324/2025-26/ 1085557847 (1) AND ENCLOSED AS ANNEXURE K3. E) QUASHING OF THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED NOTICE FOR PENALTY UNDER SECTION 274 R.W.S. 270A OF THE INCOME TAX ACT, 1961, DATED 04/02/2026 ISSUED BY R1 FOR THE ASSESSMENT YEAR 2024-25 WHICH BEARS THE DIN ITBA/PNL/S/270A/2025-26/ 1085557813(1) AND ENCLOSED AS ANNEXURE L1. F) QUASHING OF THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED NOTICE FOR PENALTY UNDER SECTION 274 R.W.S. 271AAC(1) OF THE INCOME TAX ACT, 1961, DATED 04/02/2026 ISSUED BY R1 FOR THE ASSESSMENT YEAR 2024-25 WHICH BEARS THE DIN ITBA/PNL/S/271AAC(1)/2025- 26/1085557814(1) ENCLOSED AS ANNEXURE L2.

THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD HC-KAR ORAL ORDER

After being heard for some time, Mr. Shreehari Kutsa, the learned counsel for the petitioner files a memo for withdrawal which reads as under.

"The petitioner humbly requests this Hon'ble Court t kindly permit the petitioner to withdraw this petition with liberty to file a fresh writ petition if circumstances warrant."

The petition stands disposed of without prejudice to prosecute the appeal as permissible in law.

Sd/- (B M SHYAM PRASAD) JUDGE

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