- 1 - HC-KAR NC: 2025:KHC:36138 WP No. 14686 of 2024 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. 14686 OF 2024 (T-IT) BETWEEN: SRI NAGENDRA CREDIT CO OPERATIVE SOCIETY LIMITED A REGISTERED CO-OPERATIVE SOCIETY REPRESENTED BY ITS CEO, SRI SIDDESHA K S 45 YEARS, 368/A, 6TH MAIN ROAD, NAGENDRA BLOCK, BANGALORE 560050, PAN. AADTS4884P …PETITIONER (BY SRI. RAVI SHANKAR S V.,ADVOCATE) AND: 1. INCOME TAX OFFICER WARD-5(2)(1), BANGALORE- 560 095 2. NATIONAL FACELESS ASSESSMENT CENTRE ADDITIONAL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY OF FINACNE, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110003 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX-3 THE OFFICE OF THE PRINCIPAL COMMISSIONER OF INCOME TAX-3, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:36138 WP No. 14686 of 2024 BMTC BUILDING, KORAMANGALA, BANGALORE- 560 095 …RESPONDENTS (BY SRI. M.THIRUMALESH, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE UNDER SECTION 148A(B) OF THE ACT DATED 08/02/2023 BEARING DIN NO. ITBA/AST/F/148A(SCN)/2022-23/1049551738(1) ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2019-20 HEREIN MARKED AS ANNEXURE - A., AND ETC. 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 is before this Court seeking the following prayer: “Wherefore it is prayed that this Hon'ble Court be pleased to: "i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148A(b) of the Act dated 08/02/2023 bearing DIN No. ITBA/AST/F/148A(SCN)/2022- 23/1049551738(1) Issued by the Respondent No.1 for the assessment year 2019-20 herein marked as Annexure - A. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148A(b) of the Act dated 27/02/2023 - 3 - HC-KAR NC: 2025:KHC:36138 WP No. 14686 of 2024 bearing DIN No. ITBA/AST/F/148A(SCN)/2022- 23/1050148617(1) issued by the Respondent No.1 for the assessment year 2019-20 herein marked as Annexure - A1. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order under Section 148A(d) of the Act dated 20/03/2023 bearing DIN No. ITBA/AST/F/148A/2022- 23/1050989072(1) issued by the Respondent No.1 for the assessment year 2019-20 herein marked as Annexure- A2. (v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice under Section 148 of the Act dated 20/03/2023 bearing DIN No. ITBA/AST/S/1481/2022- 23/1051007032(1) issued by the Respondent No.1 for the assessment year 2019-20 herein marked as Annexure-АЗ. v) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed U/s 147 r.w.s 144 dated 27/02/2024 bearing ITBA/AST/S/147/2023-24/1061590347(1) issued by the Respondent No. 2 for the assessment year 2019-20 herein marked as Annexure A4. vi) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice u/s 271AAC(1) of the Act dated 16/04/2024 bearing DIN No. ITBA/PNL/F/271AAC(1)/2024- 25/1064128201(1) by the Respondent No. 2 for the assessment year 2019-20 herein marked as Annexure - A5. vii) Issue a writ of Certiorart or direction in the nature of s wit of certiorari quashing the penalty notice under Section 274 FW. 2724(1)(0) of the Act dated 27/02/2024 vide ITBA/PNL/F/272A(1)(d)/2023-24/1061588463(1), d by the Respondent No.2 for the assessment year 2015-20 herein marked as Annexure - A6. - 4 - HC-KAR NC: 2025:KHC:36138 WP No. 14686 of 2024 vill) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Sri Ravishankar S.V., learned counsel for the petitioner, Sri M. Thirumalesh along with Sri Ganesh Ghale, 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. - 5 - HC-KAR NC: 2025:KHC:36138 WP No. 14686 of 2024 (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.: 0