- 1 - HC-KAR NC: 2025:KHC:49323 WP No. 21901 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 25TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO.21901 OF 2025 (T-IT) BETWEEN: TURUVANUR RANGAPPA SWAMY S/O LATE RANGAPPA AGED ABOUT 65 YEARS PAN NO.ABDPT9754A RESIDING AT NO.11, SRIRANGA NILAYA, 1ST MAIN, ACHAIAH SHETTY LAYOUT, NEAR MEKARI CIRCLE, BANGALORE – 560 080. …PETITIONER (BY SRI. RAJEEV CHANNAPPA NULVI, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD 6(2)(1), BANGALORE BMTC BUILDING, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORMANGALA, BENGALURU 560 095. 2. THE INCOME TAX OFFICER, WARD 2(1)(1), BANGALORE BMTC BUILDING, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORMANGALA, BENGALURU 560 095. 3. THE ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 6(1), BANGALORE BMTC BUILDING, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORMANGALA, BENGALURU - 560 095. …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) Digitally signed by MADHURI S Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:49323 WP No. 21901 of 2025 THIS W.P IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI, QUASHING THE IMPUGNED NOTICE DATED 28/06/2025, UNDER SEC. 148 OF THE INCOME TAX ACT, 1961, BEARING ITBA/AST/S/148-1/2025- 26/1077948044(1), ISSUED BY THE INCOME TAX OFFICER, WARD 6(2)(1), BANGALORE, PERTAINING TO ASSESSMENT YEAR 2019-20, VIDE ANNEXURE- A AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks the following reliefs: “a) To issue a writ of certiorari, quashing the impugned Notice dated 28/06/2025 under Sec.148 of the Income Tax Act, 1961, bearing DIN & Notice No: ITBA/AST/S/148_1/2025-26/1077948044(1), issued by the Income Tax Officer, Ward 6(2)(1), Bangalore, pertaining to Assessment Year 2019-20, vide Annexure: A and b) To issue a writ of certiorari, quashing the impugned order dated 28/06/2025, under Sec. 148A(3) of the Income Tax Act, 1961, bearing DIN & Notice No: ITBA/AST/F/148A/2025-26/1077947202(1) issued and passed by the respondent Authority No.1 – The Income Tax Officer, Ward 6(2)(1), Bangalore, pertaining to Assessment Year 2019-20, vide Annexure: B and c) To issue a writ of certiorari quashing the impugned Show Cause Notice dated 27/03/2025 vide DIN No. ITBA/AST/F/148A(SCN)_1/2024-25/1075138780(1) stating - 3 - HC-KAR NC: 2025:KHC:49323 WP No. 21901 of 2025 to be under Sec.148A(1) of the Income Tax Act, 1961, issued by the Respondent Authority No.2 – The Income Tax Officer, Ward 2(1)(1), Bangalore, in respect of the petitioner, pertaining Assessment Year 2019-20, vide Annexure C and d) To pass any such other writ, order or direction as this Hon’ble Court might deem fit to be issued in the fact and circumstances of the case in the interest of justice and equity.” 2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitioner invited my attention to the order of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order. 4. Per contra, learned counsel for the respondents submits that there is no merit in the petition and that the same is liable to be dismissed. - 4 - HC-KAR NC: 2025:KHC:49323 WP No. 21901 of 2025 5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under: "13. I, therefore, pass the following: O R D E R (i) The impugned show cause notices 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 these cases would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. (iv) 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." - 5 - HC-KAR NC: 2025:KHC:49323 WP No. 21901 of 2025 6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of co-ordinate Bench of this Court in Ramachandra Reddy's case supra. 7. In the result, I pass the following: ORDER (i) The petition is allowed and disposed of in terms of the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025. (ii) The impugned show cause notices and consequential orders, notices etc., at Annexures- A, B and C dated 28.06.2025, 28.06.2025 and 27.03.2025 are hereby quashed. (iii) Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, subsequent to disposal of the matters pending before the Apex Court and all rival - 6 - HC-KAR NC: 2025:KHC:49323 WP No. 21901 of 2025 contentions between the parties in this regard are kept open and no opinion is expressed on the same. Sd/- (S.R.KRISHNA KUMAR) JUDGE SV List No.: 2 Sl No.: 94