- 1 - HC-KAR NC: 2025:KHC:39431 WP No. 18019 of 2022 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28TH DAY OF AUGUST, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 18019 OF 2022 (T-IT) BETWEEN: THE CENTRAL ARECANUT AND COCOA MARKETING AND PROCESSING CO-OPERATIVE LIMITED REPRESENTED BY ITS MANAGING DIRECTOR MR.H.M.KRISHNA KUMAR AGED ABOUT 58 YEARS P.B.NO.223, VARANASHI TOWERS MISSION STREET MANGALURU – 575 001. (A CO-OPERATIVE SOCIETY REGISTERED UNDER THE MULTI-STATE CO-OPERATIVE SOCIETIES ACT, 1984) …PETITIONER (BY SRI ANNAMALAI S., ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE – 2, MANGALURU C.R.BUILDING, N.G.ROAD, ATTAWARA MANGALURU – 575 001. 2. THE DIRECTOR GENERAL OF INCOME TAX (INVESTIGATION), BENGALURU Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39431 WP No. 18019 of 2022 C.R.BUILDING ANNEXE QUEENS ROAD BENGALURU – 560 001. …RESPONDENTS (BY SRI E.I.SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE ISSUED U/S 148A(b) OF THE ACT DTD 19.05.2022 OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R1 BEARING DIN AND LETTER NO.ITBA/COM/F/17/2022- 23/1043082344(1) HEREIN MARKED AS ANNEXURE-A1; QUASH THE ORDER DTD 28.07.2022 PASSED U/S 148A(d) OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R1 BEARING DIN AND ORDER NO.ITBA/COM/F/17/2022- 23/1044250495(1) HEREIN MARKED AS ANNEXURE-A2; QUASH THE NOTICE DTD 28.07.2022 ISSUED U/S 148 OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R1 BEARING DIN AND NOTICE NO.ITBA/AST/M/148-1/2022- 23/1044253134(1) HEREIN MARKED AS ANNEXURE-A3. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39431 WP No. 18019 of 2022 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/COM/F/17/2022- 23/1043082344(1) dated 19.05.2022, ITBA/AST/M/148_1/2022-23/1044253134(1) dated 28.07.2022 and order No.ITBA/COM/F/17/2022-23/1044250495(1) dated 28.07.2022 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri E.I.Sanmathi, learned counsel for the respondents. 3. The grounds projected in the subject petition 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 case at hand, the - 4 - HC-KAR NC: 2025:KHC:39431 WP No. 18019 of 2022 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned notices bearing No.ITBA/COM/F/17/2022-23/1043082344(1) dated 19.05.2022 and ITBA/AST/M/148_1/2022- 23/1044253134(1) dated 28.07.2022 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in this petition would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive the petition in the event, the Apex Court would hold in favour of the Revenue in the matter pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petition is allowed. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be - 5 - HC-KAR NC: 2025:KHC:39431 WP No. 18019 of 2022 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 294