- 1 - HC-KAR NC: 2025:KHC:36527 WP No. 17855 of 2023 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28TH DAY OF AUGUST, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 17855 OF 2023 (T-IT) BETWEEN: SRI UDAYARAVI SOUHARDA CREDIT CO-OPERATIVE SOCIETY LTD., A CREDIT CO-OPERATIVE SOCIETY REGISTERED UNDER KARNATAKA CO-OPERATIVE SOCIETIES ACT 1959 UDAYARAVI BHAVANA, 1ST MAIN , 7TH CROSS K R EXTENSION, TIPTUR TUMKUR DISTRICT 572201. REPRESENTED BY ITS CEO S RI THIMMLAPURA CHANDRIAH RAVI SON OF CHANDRAIAH T M AGED ABOUT 49 YEARS …PETITIONER (BY SRI. SHREEHARI.,ADVOCATE) AND: 1. INCOME TAX OFFICER, WARD-1 TIPTUR, THE ‘ASSESSING OFFICER’ UNDER THE INCOME TAX ACT 1961 JAYADEVA COMPLEX TIPTUR 572201. 2. PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU 2 THE ‘SPECIFIED AUTHORITY’ UNDER Digitally signed by NAGAVENI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:36527 WP No. 17855 of 2023 THE INCOME TAX ACT, 1961, BMTC BUILDING, 80 FT ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU 560 095. …RESPONDENTS (BY SRI. SUSHAL TIWARI, ADVOCATE) THIS WP IS FILED UNDER ARTICLE 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO QUASHING OF THE NOTICE UNDER CLAUSE (B) OF SECTION 148A OF THE INCOME TAX ACT 1961 DTD 31.01.2023 FOR THE AY 2019-20 ISSUED BY THE RESPONDENT BEARING DIN VIZ ITBA/AST/F/148A(SCN)/2022-23/1049294953(1) WHICH IS ENCLOSED AS ANNX-D AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayer: “a. Invoking the extra-ordinary jurisdiction of this Hon'ble Court seeking quashing of the notice under clause (b) of section 148A of the Income Tax Act, 1961 dated 31/01/2023 for the A.Y. 2019-20 issued by the Respondent bearing DIN viz., ITBA/AST/F/148A(SCN)/2022-23/1049294953(1) which is enclosed as Annexure D. - 3 - HC-KAR NC: 2025:KHC:36527 WP No. 17855 of 2023 b. Invoking the extra-ordinary jurisdiction of this Hon'ble Court seeking quashing of the order under clause (d) of section 148A of the Income Tax Act, 1961 dated 30/03/2023 for the A.Y. 2019-20 issued by the Respondent bearing DIN viz., ITBA/AST/F/148A/2022-23/1051630748(1) which is enclosed as Annexure F. c. Invoking the extra-ordinary jurisdiction of this Hon'ble Court seeking quashing of the notice under section 148 of the Income Tax Act, 1961 dated 31/03/2023 for the A.Y. 2019-20 issued by the Respondent bearing DIN viz., ITBA/AST/S/148_1/2022-23/1051723087(1) which is enclosed as Annexure G. d. And pass such other orders as this Hon'ble court deems fit and proper in the interest of justice and equity.” 2. Heard Sri Shreehari, 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: - 4 - HC-KAR NC: 2025:KHC:36527 WP No. 17855 of 2023 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 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.: 1 Sl No.: 354