- 1 - HC-KAR NC: 2025:KHC:39425 WP No. 25163 of 2022 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. 25163 OF 2022 (T-IT) BETWEEN: CHANCHAPPA SRINIVASA MADHAMANGALA S/O SRI M.N.CHANCHAPPA AGED ABOUT 55 YEARS R/O NO.432, 4TH CROSS II BLOCK, HRBR LAYOUT KALYANANAGAR POST BENGALURU – 560 043 PAN: AMYPS0555Q. …PETITIONER (BY SRI ANNAMALAI S., ADVOCATE) AND: 1. NATIONAL FACELESS ASSESSMENT CENTRE REPRESENTED BY ADDITONAL/ JOINT/ DEPUTY/ ASSISTANT COMMISSIONER OF INCOME TAX INCOME TAX OFIFCER INCOME TAX DEPARTMENT MINISTRY OF FINANCE ROOM NO.401, 2ND FLOOR E-RAMP, JAWAHARLAL NERHU STADIUM DELHI – 110 003. 2. THE DEPUTY / ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 6(1)(1) BMTC BUILDING, 80 FEET ROAD Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39425 WP No. 25163 of 2022 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU – 560 095. 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU - 1 BMTC BUIDLING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU – 560 095. 4. THE JOINT COMMISSIONER OF INCOME TAX (OSD) OFFICE OF 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. …RESPONDENTS (BY SRI E.I.SANMATHI, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE ISSUED U/S 148A(B) OF THE ACT DATED 22.05.2022 BEARING DIN AND LETTER NO.ITBA/COM/F/17/2022-23/1043109128(1) ISSUED BY THE R2 FOR THE A Y 2016-17 HEREIN MARKED AS ANNEXURE-A1; QUASH THE ORDER DATED 27.07.2022 PASSED U/S 148A(D) OF THE ACT BEARING DIN AND ORDER NO. ITBA/COM/F/17/2022-23/1044175934(1) ISSUED BY THE R2 FOR THE A Y. 2016-17 HEREIN MARKED AS ANNEXURE-A2; QUASH THE NOTICE DATED 27.07.2022 ISSUED U/S 148 OF THE ACT BEARING DIN NO ITBA/AST/M/148_1/2022- 23/1044224417(1) ISSUED BY THE R2 FOR THE A Y 2016-17 HEREIN MARKED AS ANNEXURE-A3; QUASH THE NOTICE - 3 - HC-KAR NC: 2025:KHC:39425 WP No. 25163 of 2022 DATED 30.06.2021 ISSUED U/S 148 OF THE ACT BEARING DIN AND NOTICE NO. ITBA/AST/S/148/2021-22/1033930312(1) ISSUED BY THE R4 FOR THE AY 2016-17 HEREIN MARKED AS ANNEXURE-A4. 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 notices bearing No.ITBA/COM/F/17/2022- 23/1043109128(1) dated 22.05.2022, ITBA/AST/M/148_1/2022-23/1044224417(1) dated 27.07.2022, ITBA/AST/S/148/2021-22/1033930312(1) dated 30.06.2021 and order No.ITBA/COM/F/17/2022- 23/1044175934(1) dated 27.07.2022 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 E.I.Sanmathi, learned counsel for the respondents. - 4 - HC-KAR NC: 2025:KHC:39425 WP No. 25163 of 2022 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/COM/F/17/2022-23/1043109128(1) dated 22.05.2022, ITBA/AST/M/148_1/2022- 23/1044224417(1) dated 27.07.2022 and ITBA/AST/S/148/2021-22/1033930312(1) dated 30.06.2021 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:39425 WP No. 25163 of 2022 (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 and I.A.No.1/2022 would be considered, in the event revival of this petition becomes necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 316 CT:SS