- 1 - HC-KAR NC: 2025:KHC:39443 WP No. 6137 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. 6137 OF 2023 (T-IT) BETWEEN: SMT. GOVINDA SWAMY REDDY ROOPALATHA D/O LATE SRI GOVINDA SWAMY REDDY AGED ABOUT 59 YEARS R/O NO.25, KRISHNA REDDY COLONY DOMLUR LAYOUT, BENGALURU – 560 071 PAN: CNWPR8235D. …PETITIONER (BY SRI ANNAMALAI S., ADVOCATE) AND: 1. NATIONAL FACELESS ASSESSMENT CENTRE 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 – 110 003. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39443 WP No. 6137 of 2023 2. THE INCOME TAX OFFICER CIRCLE 1(2)(1) BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU – 560 095. 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU - 1 BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU – 560 095. …RESPONDENTS (BY SRI Y.V.RAVIRAJ AND M.DILIP, ADVOCATES) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRYING TO QUASHING THE NOTICE ISSUED UNDER SECTION 148A(B) OF THE ACT DTD 20.03.2022 BEARING DIN AND LETTER NO.ITBA/AST/F/148A(SCN)/2021-22/1041086375(1) ISSUED BY THE R-2 FOR THE ASSESSMENT YEAR 2018-19 HEREIN MARKED AS ANNX-A1; QUASHING THE ORDER DTD 29.03.2022 PASSED UNDER SECTION 148A(D) OF THE ACT BEARING DIN AND ORDER NO. ITBA/AST/F/148A/2021- 22/1041962447(1) ISSUED BY TH R-2 FOR THE ASSESSMENT YEAR 2018-19 HEREIN MARKED AS ANNX-A2; QUASHING THE NOTICE DTD 30.03.2022 ISSUED UNDER SECTION 148 OF THE ACT BEARING DIN NO.ITBA/AST/S/148-1/2021- - 3 - HC-KAR NC: 2025:KHC:39443 WP No. 6137 of 2023 22/1042030084(1) ISSUED BY THE R-2 FOR THE ASSESSMENT YEAR 2018-19 HEREIN MARKED AS ANNX-A3; 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/F/148A(SCN)/2021-22/1041086375(1) dated 20.03.2022, ITBA/AST/S/148_1/2021-22/1042030084(1) dated 30.03.2022 and order No.ITBA/AST/F/148A/2021- 22/1041962447(1) dated 29.03.2022 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri Y.V.Raviraj and Sri M. Dilip, learned counsel for the respondents. - 4 - HC-KAR NC: 2025:KHC:39443 WP No. 6137 of 2023 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/F/148A(SCN)/2021-22/1041086375(1) dated 20.03.2022 and ITBA/AST/S/148_1/2021- 22/1042030084(1) dated 30.03.2022 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. - 5 - HC-KAR NC: 2025:KHC:39443 WP No. 6137 of 2023 (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.: 325 CT:SS