- 1 - HC-KAR NC: 2025:KHC:39691 WP No. 23626 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. 23626 OF 2024 (T-IT) BETWEEN: GAYATHRI D/O G.NAGARAJA, AGED ABOUT 37 YEARS NO.1, RMC ROAD, 1ST MAIN, 2ND CROSS, JOG ROAD, SAGAR TALUKA, SHIVAMOGGA – 577 401. …PETITIONER (BY SMT. LOCHANA S. BABU, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD-1 AND TPS, SHIVAMOGGA, IT OFFICE, SHIVAMOGGA, NO. 75, 100FT ROAD, GOPAL GOWDA EXTEN., SHIVAMOGGA – 577 201. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU - 1, C.R. BUILDING, QUEENS ROAD, BENGALURU – 560 001. …RESPONDENTS (BY SRI M.DILIP, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39691 WP No. 23626 of 2024 THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE ISSUED UNDER SECTION 148A(b) OF THE ACT DATED 31.03.2024 OF THE ACT FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO.1 BEARING DIN AND NOTICE NO.ITBA/AST/F/148A(SCN)/2023- 24/1063778091(1) HEREIN MARKED AS ANNEXURE – A; B) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE ISSUED UNDER SECTION 148A(b) OF THE ACT DATED 09.04.2024 OF THE ACT FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO.1 BEARING DIN AND NOTICE NO.ITBA/AST/F/148A(SCN)/2024-25/1064011394(1)HEREIN MARKED AS ANNEXURE - A1; C) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE ORDER DATED 14.04.2024 PASSED UNDER SECTION 148A(d) OF THE ACT FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO.1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A/2024- 25/1064079608(1) HEREIN MARKED AS ANNEXURE - A2; D)ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE DATED 14.04.2024 ISSUED UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO.1 BEARING DIN AND NOTICE NO. ITBA/AST/S/148_1/2024- 25/1064079615(1) HEREIN MARKED AS ANNEXURE - A3. - 3 - HC-KAR NC: 2025:KHC:39691 WP No. 23626 of 2024 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/AST/F/148A(SCN)/2023-24/1063778091(1) dated 31.03.2024, ITBA/AST/F/148A(SCN)/2024-25/1064011394(1) dated 09.04.2024, ITBA/AST/S/148_1/2024- 25/1064079615(1) dated 14.04.2024 and order No.ITBA/AST/F/148A/2024-25/1064079608(1) dated 14.04.2024 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Smt. Lochana S. Babu, 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 - 4 - HC-KAR NC: 2025:KHC:39691 WP No. 23626 of 2024 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)/2023-24/1063778091(1) dated 31.03.2024, ITBA/AST/F/148A(SCN)/2024- 25/1064011394(1) dated 09.04.2024 and ITBA/AST/S/148_1/2024-25/1064079615(1) dated 14.04.2024 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. (iii) With the aforesaid liberty and to the aforesaid extent, the petition is allowed. - 5 - HC-KAR NC: 2025:KHC:39691 WP No. 23626 of 2024 (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.: 2 Sl No.: 50