- 1 - HC-KAR NC: 2025:KHC:39282 WP No. 28170 of 2025 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. 28170 OF 2025 (T-IT) BETWEEN: 1. MR. KADA AGRAHARA CHOWDAREDDY JAYAPRAKASH SON OF LATE CHOWDA REDDY, AGED ABOUT 51 YEARS, RESIDING AT NO. 58, CHOWDESHWARI NILAYA, KADA AGRAHARA VILLAGE, ANEKAL TALUK, BANGALORE - 562 125 2. SMT. MANJULA S.L. WIFE OF SRI K V SRINIVASA REDDY, AGED ABOUT 43 YEARS, RESIDING AT NO. 15, NEAR SHIVA TEMPLE, KACHAMARANAHALLI, GUNJUR, BANGALORE - 560 087 …PETITIONERS (BY SRI. SANDEEP HUILGOL, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39282 WP No. 28170 of 2025 AND: 1. INCOME-TAX OFFICER WARD 4(2)(3), BANGALORE, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560 095 2. JOINT COMMISSIONER OF INCOME TAX RANGE-4 (1), BANGALORE, NO. 59, HMT BHAVAN, 4TH FLOOR, BALLARI ROAD, GANGANAGAR, BANGALORE - 560 032 …RESPONDENTS (BY SRI. SUSHAL TIWARI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO (I) QUASHING THE IMPUGNED NOTICE DATED 28.06.2025 BEARING NO. ITBA/AST/S/148-1/2025-26/1077964886(1) ISSUED BY THE 1ST RESPONDENT UNDER SECTION 148 OF THE INCOME-TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2015-16 (ANNEXURE- A) AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39282 WP No. 28170 of 2025 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioners are before this Court, seeking the following prayer: “(i) Quashing the Impugned Notice dated 28.06.2025 bearing No. ITBA/AST/S/148_1/2025- 26/1077964886(1) issued by the 1st Respondent under Section 148 of the Income-Tax Act, 1961 for the Assessment Year 2015-16 (Annexure - 'A'); (ii) Quashing the Impugned Notice dated 28.06.2025 bearing No. ITBA/AST/S/148_1/2025- 26/1077964993(1) issued by the 1st Respondent under Section 148 of the Income-Tax Act, 1961 for the Assessment Year 2015-16 (Annexure - 'A1'); (iii) Quashing the Impugned Order dated 28.06.2025 bearing No.ITBA/AST/F/148A/2025- 26/1077954631(1) passed by the 1st Respodent under Section 148A(3) of the Income-Tax Act, 1961 for the Assessment Year 2015-16 (Annexure - 'B'); (iv) Quashing the Impugned Order dated 28.06.2025 bearing No.ITBA/AST/F/148A/2025- 26/1077954567(1) passed by the 1st Respondent under Section 148A(3) of the Income-Tax Act, 1961 for the Assessment Year 2015-16 (Annexure - 'B-1'); (v) Pass such order or further orders as this Hon'ble Court may deem fit in the facts and circumstances of the case, and in the interests of justice and equity." - 4 - HC-KAR NC: 2025:KHC:39282 WP No. 28170 of 2025 2. eard Sri Sandeep Huilgol, learned counsel for the petitioners and Sri Sushal Tiwari, 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 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned show cause notice 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 this petition would stand quashed. - 5 - HC-KAR NC: 2025:KHC:39282 WP No. 28170 of 2025 (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 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE SJK CT:SG List No.: 5 Sl No.: 24