- 1 - HC-KAR NC: 2025:KHC:38147 WP No. 20679 of 2022 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 20679 OF 2022 (T-IT) BETWEEN: M/S AKHILA BHARATH SRI VASAVI PENUGONDA TRUST REPRESENTED BY ITS TREASURER N S SRINIVASA MURTHY S/O N K SUBBAIAH SETTY AGED ABOUT 72 YEARS NO.23A, VASAVI NILAYA SERPENTINE ROAD KUMARA PARK WEST BANGALORE-560020 …PETITIONER (BY SRI. ANNAMALAI S., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(4) BANGALORE 3RD FLOOR, CENTRAL CIRCLE-2(4) BENGALURU 2. THE DIRECTOR GENERAL INCOME TAX(INV) CENTRAL REVENUE BUILDING QUEENS ROAD BENGALURU-560 001 …RESPONDENTS (BY SRI. RAVI RAJ Y V., ADVOCATE) THIS WP FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE NOTICE ISSUED UNDER SECTION 148(b) OF THE ACT DATED Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:38147 WP No. 20679 of 2022 18.05.2022 OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE RESPONDENT NO.1 BEARING DIN AND LETTER NO. ITBA/COM/F/17/2022-23/1043059333(1) HEREIN MARKED AS ANNEXURE-A1. 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: "i) Issue a writ of Certiorari or direction in the nature of a wit of certiorari quashing the notice issued under section 148A(b) of the Act dated 18.05.2022 of the Act for the assessment year 2015-16 by the Respondent No.1 bearing DIN & Letter No. ITBA/COM/F/17/2022-23/1043059333(1) herein marked as Annexure - A1. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 29.07.2022 passed under section 148A(d) of the Act for the assessment year 2015-16 by the Respondent No.1 bearing DIN & Order No. ITBA/COM/F/17/2022- 23/1044289401(1) herein marked as Annexure - A2. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 29.07.2022 issued under section 148 of the Act for the assessment year 2015-16 by the Respondent No.1 bearing DIN & Document No. ITBA/AST/M/148_1/2022-23/1044310001(1) herein marked as Annexure-A3. - 3 - HC-KAR NC: 2025:KHC:38147 WP No. 20679 of 2022 iv) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Sri Annamalai S., 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 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned show cause notices 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. - 4 - HC-KAR NC: 2025:KHC:38147 WP No. 20679 of 2022 (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 BSV List No.: 1 Sl No.: 207