- 1 - HC-KAR NC: 2025:KHC:38154 WP No. 1295 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 1295 OF 2024 (T-IT) BETWEEN: CENTRAL TAX AND CUSTOMS STAFF CREDIT CO OPERATIVE SOCIETY LIMITED A COOPERATIVE SOCIETY REGISTERED UNDER KARNATKA CO-OPERATIVE SOCIETIES ACT, 1959 REPRESENTED HEREIN BY ITS SECRETARY SHRI. BHASKARA A.L. HAVING ITS REGISTERED OFFICE AT CR BUILDING, ANNEXE II, D BLOCK BASEMENT, QUEENS ROAD, BANGALORE-560 001 ALSO AT ALUR VILLARE AND POST, KASABA HOBLI, MADDUR TALUK, MANDYA DISTRICT, ALUR, MANDYA- 571433. …PETITIONER (BY SRI. SANDEEP HUILGOL, ADVOCATE) AND: 1. THE ASSESSMENT UNIT/VERIFICATION UNIT TECHNICAL UNIT/ REVIEW UNIT, INCOME TAX DEPARTMENT, 2ND FLOOR, JAWAHARLAL NEHRU STADIUM NEW DELHI-110003 2. INCOME TAX OFFICER Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:38154 WP No. 1295 of 2024 WARD 1(2)(1), BANGALORE, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BANGALORE-560095 3. PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU-I, BENGALURU C R BUILDING, NO. 1, QUEENS ROAD, BANGALORE-560001 …RESPONDENTS (BY SRI. SUSHAL TIWARI, ADVOCATE) THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE IMPUGNED ORDER DATED 31/03/2023 PASSED BY R2 UNDER SECTION 148A(d) OF THE ACT, BEARING NO. ITBA/AST/F/148A/2022- 23/1051732946(1) FOR THE SUBJECT AY 2019-20 (ANNEXURE- D)., 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 M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/AST/S/148_1/2022- 23/1051738960(1) dated 31.03.2023, - 3 - HC-KAR NC: 2025:KHC:38154 WP No. 1295 of 2024 ITBA/AST/S/148_1/2022-23/1051738960(1) dated 31.03.2023 and order No.ITBA/AST/F/148A/2022-23/1051732946(1) dated 31.03.2023 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Sandeep Huilgol, learned counsel for the petitioner 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 notices bearing No. ITBA/AST/S/148_1/2022-23/1051738960(1) dated - 4 - HC-KAR NC: 2025:KHC:38154 WP No. 1295 of 2024 31.03.2023 and ITBA/AST/S/148_1/2022- 23/1051738960(1) dated 31.03.2023 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stands 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. (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 BSV List No.: 1 Sl No.: 0