- 1 - HC-KAR NC: 2025:KHC:42608 WP No. 32093 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 27TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 32093 OF 2025 (T-IT) BETWEEN: KARNATAKA CO OPERATIVE SHEEP AND GOAT REARERS SOCIETIES FEDERATION LIMITED A SOCIETY FORMED AS ASSOCIATION OF PERSONS HAVING ITS REGISTERED OFFICE AT KURIBHAVANA VETERINARY COLLEGE CAMPUS, HEBBAL, BENGALURU – 560 024 (PAN AADAK4279M) REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, DR UMESY YADAV M., AGED ABOUT 42 YEARS, DESIGNATION CEO, R/AT BB-72, KHB COLONY, KAVALBIRASANDRA, BENGALURU-560032 REGISTERED UNDER THE KARNATAKA CO-OPERATIVE SOCIETY ACT, 1959 …PETITIONER (BY SRI. B.S. BALACHANDRAN, ADVOCATE) AND: 1. INCOME TAX OFFICER WARD 6(3) (1), BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095 2. THE ASSESSMENT UNIT INCOME TAX DEPARTMENT, 2ND FLOOR, JAWAHARLAL NEHRU STADIUM, NEW DELHI – 110 003 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU-6, BMTC BUILDING, Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:42608 WP No. 32093 of 2025 80 FT ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095 4. THE MANAGER THE KARNATAKA STATE CO OPERATIVE APEX BANK LIMITED, NO.18/2, 5TH MAIN ROAD, GANGENAHALLI LAYOUT, BENGALURU – 560 032 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONTITUTION OF INDIA PRAYING TO ANNEXURE – A - IMPUGNED NOTICE DATED 25.01.2024 ISSUED BY RESPONDENT NO.1 UNDER SECTION 148A(B) OF THE ACT FOR AY 2017-18 IN DIN AND NOTICE ITBA/AST/F/148A(SCN)/2023-24/1060097059(1) AND ETC., THIS PETITION, COMING ON FOR FINAL HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks for the following reliefs:- “i. Issue a writ of certiorari or any other writ as the Hon’ble High Court may deem fit and quash the following: ANNEXURE ‘A’ Impugned notice dated 25.01.2024 issued by Respondent No.1 under section 148A(b) of the Act for AY 2017- 18 in DIN & Notice No. ITBA/AST/F/148A(SCN)/2023- 24/1060097059(1). - 3 - HC-KAR NC: 2025:KHC:42608 WP No. 32093 of 2025 ANNEXURE ‘A1’ Impugned notice dated 11.02.2024 issued by Respondent No.1 under section 148A(b) of the Act for AY 2017- 18 in DIN & Notice No. ITBA/AST/F/148A(SCN)/2023- 24/1060764733(1) ANNEXURE ‘A2’ Impugned notice dated 12.03.2024 issued by Respondent No.1 under section 148A(b) of the Act for AY 2017- 18 in DIN & Notice No. ITBA/AST/F/148A(SCN)/2023- 24/1062423403(1) ANNEXURE ‘B’ Impugned order dated 21.03.2024 issued by Respondent No.1 under section 148A(d) of the Act for AY 2017- 18 in DIN & Order No. ITBA/AST/F/148A/2023- 24/1063117566(1) ANNEXURE ‘C’ Impugned notice dated 21.03.2024 issued by Respondent No.1 under section 148 of the Act for AY 2017-18 in DIN & Notice No. ITBA/AST/S/148_1/2023- 24/1063118128(1) ANNEXURE ‘G’ Impugned assessment order dated 28.02.2025 passed by Respondent No.2 under section 147 read with section 144 - 4 - HC-KAR NC: 2025:KHC:42608 WP No. 32093 of 2025 read with section 144B of the Act for AY 2017-18 in DIN & Order No. ITBA/AST/S/147/2024- 25/1073852877(1) ANNEXURE ‘G1’ Impugned computation sheet dated 28.02.2025 issued by Respondent No.2 under section 147 read with section 144 of the Act for AY 2017-18 in DIN & Document No. ITBA/AST/S/215/2024- 25/1073853116(1) Annexure ‘G2’ Impugned demand notice dated 28.02.2025 issued by Respondent No.1 under section 156 of the Act for AY 2017-18 in DIN & Notice No. ITBA/AST/S/156/2024- 25/1073852963(1) ANNEXURE ‘H’ Impugned garnishee notice dated 07.10.2025 issued by Respondent No.1 under section 226(3) to Respondent No.4 for attachment of Petitioner’s bank account in DIN & Notice No. ITBA/RCV/S/226(3)_1/2025- 26/1081497074(1) ii. Lift the bank attachment placed by Respondent No.1 on the following bank accounts of the Petitioner vide the impugned garnishee notice dated 07.10.2025 issued under section 226(3) in DIN & Notice No. - 5 - HC-KAR NC: 2025:KHC:42608 WP No. 32093 of 2025 ITBA/RC/S/226(3)_1/2025-26/1081497074(1) (ANNEXURE ‘H’); Bank Account Number Account Type The Karnataka State Co- operative Apex Bank Limited 10251110200000251 Saving The Karnataka State Co- operative Apex Bank Limited 1025102040000041 Saving iii. Issue any other writ, order or direction to which the Petitioner is found entitled to in the present facts and circumstances and in the interests 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. - 6 - HC-KAR NC: 2025:KHC:42608 WP No. 32093 of 2025 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. 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. - 7 - HC-KAR NC: 2025:KHC:42608 WP No. 32093 of 2025 (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." 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, A1, A2, B, C, G, G1, G2 and H dated 25.01.2024, 11.02.2024, 12.03.2024, 21.03.2024, 21.03.2024, 28.02.2025, 28.02.2025, - 8 - HC-KAR NC: 2025:KHC:42608 WP No. 32093 of 2025 28.02.2025 and 07.10.2025 respectively, 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 contentions between the parties in this regard are kept open and no opinion is expressed on the same. Sd/- (S.R.KRISHNA KUMAR) JUDGE BMC List No.: 2 Sl No.: 24