- 1 - HC-KAR NC: 2025:KHC:39276 WP No. 28687 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. 28687 OF 2025 (T-IT) BETWEEN: 1. SHRI. SRINIVASA PUTTAGUNTA S/O SHRI P. SHIVARAMAKRISHNAPRASAD AGED ABOUT 46 YEARS NO. 257/7, NEAR THIRUMALA BAR, DOLLARS COLONY, SHAMANUR, DAVANAGERE - 577 004. …PETITIONER (BY SMT. LOCHANA S. BABU, ADVOCATE) AND: 1. INCOME TAX OFFICER WARD-1, SHREE TOWERS, HADADI MAIN ROAD, OPP. DRR HOSPITAL, DAVANAGERE - 577 002. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39276 WP No. 28687 of 2025 2. ADDITIONAL/JOINT COMMISSIONER OF INCOME TAX RANGE - 1(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE SHOW CAUSE NOTICE DATED 29.03.2025 ISSUED UNDER SECTION 148A(1) OF THE ACT, 1961 FOR THE AY 2021-22 BY THE R-1 BEARING DIN ITBA/AST/F/148A(SCN)-1/2024-25/1075235056, HEREIN MARKED AS ANNX-A. QUASH THE ORDER DATED 23.06.2025 PASSED UNDER SECTION 148A(3) OF THE ACT FOR THE AY 2021-22 BY THE R-1 BEARING DIN ITBA/AST/F/148A/2025-26/1077386135(1) HEREIN MARKED AS ANNX-A1 AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39276 WP No. 28687 of 2025 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court, seeking the following prayer: "a) Issue a Writ of Certiorari or direction in the nature of a Writ of Certiorari quashing the show cause notice dated 29.03.2025 issued under section 148A(1) of the Act, 1961 for the AY 2021-22 by the Respondent No. 1, bearing DIN ITBA/AST/F/148A(SCN)_1/2024-25/1075235056, herein marked as Annexure - A. b) Issue a Writ of Certiorari or direction in the nature of a Writ of Certiorari quashing the order dated 23.06.2025 passed under section 148A(3) of the Act for the AY 2021-22 by the Respondent No. 1 bearing DIN ITBA/AST/F/148A/2025- 26/1077386135(1), herein marked as Annexure - A1. c) Issue a Writ of Certiorari or direction in the nature of a Writ of Certiorari quashing the show cause notice dated 23.06.2025 issued under section 148 of the Act for the AY 2021-22 by the Respondent No. 1 bearing DIN ITBA/AST/S/148_1/2025- 26/1077387380(1), herein marked as Annexure A2. d) And pass such other orders and grant such other reliefs as this Hon'ble High Court deems fit including the cost of this Writ Petition in the interest of justice and equity." - 4 - HC-KAR NC: 2025:KHC:39276 WP No. 28687 of 2025 2. Heard Smt. Lochana S. Babu, , learned counsel for the petitioner and Sri M. Dilip, 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. (ii) Liberty is reserved to the respondents - revenue to revive the petition in the event, the Apex Court - 5 - HC-KAR NC: 2025:KHC:39276 WP No. 28687 of 2025 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.: 28