- 1 - HC-KAR NC: 2025:KHC-D:15051 WP No. 108165 of 2025 IN THE HIGH COURT OF KARNATAKA, AT DHARWAD DATED THIS THE 5TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 108165 OF 2025 (T-IT) BETWEEN: K V G BANK EMPLOYEES COOP CREDIT SOCIETY LIMITED, (REGISTERED UNDER THE KARNATAKA CO-OPERATIVE SOCIETIES ACT 1959) II FLOOR SHANKAR PLAZA, P.B ROAD, DHARWAD 580001, KARNATAKA, REPRESENTED BY ITS SECRETARY, SHRI. SANTOSH IRAYYA CHIKKAMATH, AGED ABOUT 43 YEARS …PETITIONER (BY SRI. PRANAV SUKHADEO KATAGERI, ADVOCATE) AND: 1. INCOME TAX OFFICER, WARD 1 (1), NAVANAGAR, HUBLI-580025, KARNATAKA 2. THE CHIEF COMMISSIONER OF INCOME TAX C.R.BUILDING, NO.1, QUEEN’S ROAD, BENGALURU 560001, KARNATAKA. …RESPONDENTS (BY SRI.M. THIRUMALESH AND SMT. ROOPA R.A., ADVOCATES) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A. QUASH BY AN ORDER, WRIT IN THE NATURE OF CERTIORARI, OR ANY OTHER WRIT OR DIRECTION THE ORDER PASSED U/S VISHAL NINGAPPA PATTIHAL Digitally signed by VISHAL NINGAPPA PATTIHAL Location: High Court of Karnataka Dharwad Bench Date: 2025.11.07 11:53:50 +0530 - 2 - HC-KAR NC: 2025:KHC-D:15051 WP No. 108165 of 2025 119(2)(B) OF THE ACT BEARING DIN AND ORDER NO.ITBA/COM/M/17/2024-25/1071875131(1) DATED 16.12.2024 FOR AY. 2021-22 IN ANNEXURE-“B” PASSED BY THE 2ND RESPONDENT AS UNLAWFUL AND ILLEGAL ALONG WITH THE ATTENDANT ACTIONS. B. QUASH BY AN ORDER, WRIT, OR DIRECTION IN THE NATURE OF CERTIORARI THE PROFORMA OF APPROVAL BY SPECIFIED AUTHORITY FOR ISSUANCE OF ORDER U/S 148A(3)/NOTICE U/S 148 OF THE ACT DATED 25.03.2025 FOR AY 2021-22 BEARING DIN ITBA/AST/S/128/ 2024-25/1075002792(1) IN ANNEXURE-“C” ISSUED BY THE 1ST RESPONDENT AS UNLAWFUL AND ILLEGAL ALONG WITH THE ATTENDANT ACTIONS. C. QUASH BY AN ORDER, WRIT, OR DIRECTION IN THE NATURE OF CERTIORARI THE NOTICE UNDER SECTION 148 DATED 29.03.2025 FOR THE AY 2021-22 BEARING DIN ITBA/AST/S/ 148_1/2024-25/1075248272(1) IN ANNEXURE-“D” ISSUED BY THE 1ST RESPONDENT AS UNLAWFUL AND ILLEGAL ALONG WITH THE ATTENDANT ACTIONS. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP THIS DAY, ORDER WAS MADE THEREIN AS UNDER: ORAL ORDER (PER: THE HON'BLE MR. JUSTICE M.NAGAPRASANNA) The petitioner - Assessee is before this Court seeking quashment of notices bearing DIN No. ITBA/COM/M/17/2024- 25/1071875131(1) dated 16.12.2024 passed by respondent No.2 under Section 119(2)(b) of the Income Tax Act, 1961, DIN No. ITBA/AST/S/128/ 2024-25/1075002792(1) dated 25.03.2025 and DIN No. ITBA/AST/S/ 148_1/2024-25/1075248272(1) dated 29.03.2025, passed by respondent No. 1 under Section 148 of the Income Tax Act, 1961. - 3 - HC-KAR NC: 2025:KHC-D:15051 WP No. 108165 of 2025 2. Heard Sri Pranav S Katageri, learned counsel for the petitioner and Sri M. Thirumalesh & Smt.Roopa R.A., learned counsels 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 DIN No. ITBA/COM/M/17/2024-25/1071875131(1) dated 16.12.2024, DIN No. ITBA/AST/S/128/ 2024- 25/1075002792(1) dated 25.03.2025 and DIN No. ITBA/AST/S/ 148_1/2024-25/1075248272(1) dated 29.03.2025, issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated - 4 - HC-KAR NC: 2025:KHC-D:15051 WP No. 108165 of 2025 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 AC CT:ANB List No.: 1 Sl No.: 144