- 1 - HC-KAR NC: 2025:KHC:39209 WP No. 12952 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. 12952 OF 2024 (T-IT) BETWEEN: MANTRI PARADISE APARTMENT OWNERS' ASSOCIATION, A SOCIETY REGISTERED UNDER THE SOCIETIES ACT, 1960, HAVING ITS OFFICE AT 148/1, 148/2, MANTRI PARADISE, BANNERGHATTA ROAD, AREKERE, BENGALURU-560076. REPRESENTED BY IS TREASURER, MR. VENKATRAMAN GANESH ILYER. …PETITIONER (BY SRI. SYED KHAMRUDDIN, ADVOCATE) AND: 1. INCOME TAX OFFICER, WARD 4(3)(1), BANGALORE, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, NEXT TO KHB GAMES VILLAGE, BENGALURU-560095. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39209 WP No. 12952 of 2024 2. ASSESSMENT UNIT, REPRESENTED BY ADDITIONAL/JOINT/ DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110003. 3. NATIONAL FACELESS APPEAL CENTRE, REP. BY ADDITIONAL/JOINT/DEPUTY/ ASSISTANT COMMISSIONER OF INCOME TAX/INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110003. …RESPONDENTS (BY SRI. M.DILIP, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE DTD. 27.02.2023 BEARING DIN NO. ITBA/AST/F/148A(SCN)2022-23/1050166032(1) UNDER SECTION 148A(b) OF THE IT ACT ISSUED BY THE 1ST RESPONDENT (ANNEXURE-A) AND NOTICE DATED 17.03.2023 BEARING DIN NO.ITBA/AST/F/148A(SCN)/2022- 23/1050915921(1) UNDER SECTION 148A(b) OF THE IT ACT ISSUED BY THE 1ST RESPONDENT (ANNEXURE-A1) AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39209 WP No. 12952 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “i. Quash the Notice dated 27.02.2023 bearing DIN No. ITBA/AST/F/148A(SCN)/2022-23/1050166032(1) under Section 148A(b) of the IT Act issued by the 1st Respondent (ANNEXURE - A) and Notice dated 17.03.2023 bearing DIN No. ITBA/AST/F/148A(SCN)/2022-23/1050915921(1) under Section 148A(b) of the IT Act issued by the 1st Respondent (ANNEXURE - A1). ii. Quash the Order dated 29.03.2023 bearing DIN No. ITBA/AST/F/148A/2022-23/1051581156(1) under Section 148A(d) of the IT Act passed by the 1st Respondent (ANNEXURE - B) and consequent notice dated 30.03.2023 bearing DIN No. ITBA/AST/S/148_1/2022-23/1051638212(1) under Section 148 of the IT Act issued by the 1st Respondent (ANNEXURE - B1). iii. Quash the Assessment Order dated 30.03.2024 bearing No.ITBA/AST/S/147/2023-24/1063716020(1) along with Computation Sheet issued by the 1st Respondent (ANNEXURE - C and C1) and the Demand Notice dated 30.03.2024 bearing No. ITBA/AST/S/156/2023-24/1063716095(1) issued by the 1st Respondent (ANNEXURE - D). iv. Quash the Notice for Penalty dated 30.03.2024 bearing No. ITBA/PNL/S/270A/2023-24/1063716156(1) issued by the 1st Respondent (ANNEXURE – E). V. Pass such other or further order as this Hon'ble Court may deem fit in the facts and circumstances of the case, and in the interests of justice and equity.” - 4 - HC-KAR NC: 2025:KHC:39209 WP No. 12952 of 2024 2. Heard Sri.Syed Khamruddin, learned counsel for the petitioner and Sri.M.Dilip, 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 show cause notice 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 - 5 - HC-KAR NC: 2025:KHC:39209 WP No. 12952 of 2024 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 CBC List No.: 2 Sl No.: 28