- 1 - HC-KAR NC: 2025:KHC:39702 WP No. 18590 of 2024 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. 18590 OF 2024 (T-IT) BETWEEN: SRI KUNDAN MAL GANNA S/O SHANKARLAL GANNA AGED ABOUT 55 YEARS NO.130, 4TH CROSS, 9TH MAIN, INDIAN OIL PETROL BUNK GOKULA, 1ST STAGE, 2ND PHASE, BENGALURU - 560 054. …PETITIONER (BY SRI NARENDRA KUMAR JAYANTILAL JAIN, ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6 (1) (1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA BENGALURU - 560 095. 2. THE ADDITIONAL / JOINT/ DEPUTY ASSISTANT COMMISSIONER OF INCOME TAX INCOME TAX OFFICER, NATIONAL FACELESS-ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39702 WP No. 18590 of 2024 MINISTRY OF FINANCE ROOM NO.401, 2ND FLOOR, E RAMP JAWAHARLAL NEHRU STADIUM DELHI - 110 003. …RESPONDENTS (BY SRI Y.V.RAVIRAJ, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH AS FAR AS THE PETITIONER IS CONCERNED BY AN APPROPRIATE WRIT OR ORDER IN THE NATURE OF CERTIORARI OR OTHERWISE THE IMPUGNED ORDER DTD. 31.03.2024 ISSUED BY THE LEARNED R-1 UNDER SECTION 148A(d) VIDE DIN ITBA/AST/F/148A/2023-24/1063769907(1) FOR AY 2017-18 ENCLOSED IN ANNEXURE-A; QUASH AS FAR AS THE PETITIONER IS CONCERNED BY AN APPROPRIATE WRIT OR ORDER IN THE NATURE OF CERTIORARI OR OTHERWISE THE IMPUGNED NOTICE UNDER SECTION 148 DTD. 31.03.2024 FOR REASSESSMENT OF INCOME, ISSUED BY THE LEARNED R-1 VIDE DIN ITBA/AST/S/148_1/2023-24/1063776977(1) FOR THE AY 2017-18 ENCLOSED IN ANNEXURE-B. - 3 - HC-KAR NC: 2025:KHC:39702 WP No. 18590 of 2024 THIS PETITION, COMING ON FOR PRELIMINARY HEARING, 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 notice bearing DIN No.ITBA/AST/S/148_1/2023- 24/1063776977(1) dated 31.03.2024 and order No.ITBA/AST/F/148A/2023-24/1063769907(1) dated 31.03.2024 passed by the respondents – Revenue under Sections 148 and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Narendra Kumar Jayantilal Jain, learned counsel for the petitioner and Sri Y.V.Raviraj, 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 - 4 - HC-KAR NC: 2025:KHC:39702 WP No. 18590 of 2024 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned notice bearing DIN No. ITBA/AST/S/148_1/2023-24/1063776977(1) dated 31.03.2024 issued by the jurisdictional Assessing Officer outside the scope of Section 151A 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 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 NVJ List No.: 2 Sl No.: 40