- 1 - HC-KAR NC: 2025:KHC:39692 WP No. 23861 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 23861 OF 2024 (T-IT) BETWEEN: MR.N.SRINIVASA S/O LATE NARAYANA SETTY AGED ABOUT 64 YEARS, RESIDING AT NO.296, 16TH CROSS, SADASHIVANAGAR, BENGALURU – 560 080. …PETITIONER (BY SRI ALOKE MADAPPA, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX JCIT (OSD) CIR 6 (1) (1) BLR, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA BENGALURU - 560 095. 2. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1(3), BLR CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU – 560 001. 3. PRINCIPAL COMMISSIONER OF INCOME TAX - 1 BMTC BUILDING, 80 FEET ROAD, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39692 WP No. 23861 of 2024 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA BENGALURU - 560 095. 4. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX - 1 KARNATAKA AND GOA REGION, GROUND FLOOR, CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001. 5. ASSESSMENT UNIT REPRESENTED BY ADDITIONAL / JOINT/ DEPUTY / ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E - RAMP, JAWARHARLAL NEHRU STADIUM DELHI – 110 003. 6. NATIONAL FACELESS ASSESSMENT CENTRE REPRESENTED BY ADDITIONAL / JOINT/ DEPUTY / ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E - RAMP, JAWAHARLAL NEHRU STADIUM DELHI – 110 003. …RESPONDENTS (BY SRI Y.V.RAVIRAJ, ADVOCATE) - 3 - HC-KAR NC: 2025:KHC:39692 WP No. 23861 of 2024 THIS W.P. IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE UNDER SECTION 148 DTD. 30.06.2021 BEARING ITBA/AST/S/148/2021-22/1033886294(1) ISSUED BY THE R-1 (ANNX-A); QUASH THE NOTICE DTD. 25.05.2022 BEARING NO. ITBA/COM/17/2022-23/1043168724(1) (ANNEXURE-A1); QUASH THE NOTICE UNDER SECTION 148A(d) OF THE I.T.ACT DTD. 29.07.2022 BEARING NO. ITBA/COM/F/17/2022- 23/1044298169(1) ISSUED BY THE R-2 (ANNEXURE-B) AND THE CONSEQUENT NOTICE UNDER SECTION 148 DTD. 29.07.2022 (ANNEXURE-B1) ALONG WITH INTIMATION LETTER DTD. 29.07.2022 BEARING NO.ITBA/AST/S/91/2022- 23/1044305780(1) (ANNX-B2); QUASH THE ASSESSMENT ORDER DTD. 30.05.2023 BEARING NO. ITBA/AST/S/147/2023- 24/1053330754(1) (ANNEXURE-C) ALONG WITH COMPUTATION SHEET DTD. 30.05.2023 BEARING NO.ITBA/AST/S/114/2023-24/1053330802(1) AND THE DEMAND NOTICE DTD. 30.05.2023 BEARING NO. ITBA/AST/S/156/2023-24/1053330842(1) (ANNEXURE-C1 AND C2) ISSUED BY THE R-2; QUASH THE NOTICE U/S 274 R/W SECTION 271(1)(c) DTD. 12.03.2024 BEARING NO. ITBA/PNL/S/271(1)(c)/2023-24/1062465276(1) ISSUED BY THE R-2 (ANNEXURE-D). THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 4 - HC-KAR NC: 2025:KHC:39692 WP No. 23861 of 2024 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- 23/1043168724(1) dated 25.05.2022, ITBA/COM/F/17/2022- 23/1044298169(1) dated 29.07.2022, ITBA/PNL/S/271(1)(c)/2023-24/1062465276(1) dated 12.03.2024, intimation letter No.ITBA/AST/S/91/2022- 23/1044305780(1) dated 29.07.2022 and order No.ITBA/AST/S/147/2023-24/1053330754(1) dated 30.05.2023 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Aloke Madappa, learned counsel for the petitioner and Sri Y.V.Raviraj, 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 - 5 - HC-KAR NC: 2025:KHC:39692 WP No. 23861 of 2024 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 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned notices bearing No. ITBA/COM/F/17/2022-23/1043168724(1) dated 25.05.2022, ITBA/COM/F/17/2022- 23/1044298169(1) dated 29.07.2022, ITBA/PNL/S/271(1)(c)/2023-24/1062465276(1) dated 12.03.2024 and intimation letter No.ITBA/AST/S/91/2022-23/1044305780(1) dated 29.07.2022 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. - 6 - HC-KAR NC: 2025:KHC:39692 WP No. 23861 of 2024 (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 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 2 Sl No.: 51