- 1 - HC-KAR NC: 2025:KHC:39713 WP No. 14784 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. 14784 OF 2024 (T-IT) BETWEEN: SRI T.M.SHIVANANDA S/O MANJAPPA BELIMALLURUR AGED ABOUT 50 YEARS BELIMALLURU MAIN ROAD NEAR TEMPLE, HONNALI – 577 217 DAVANAGERE DISTRICT. …PETITIONER (BY SRI RAMA MURTHY R., ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD – 1, SHREE TOWERS HADADI MAIN ROAD DAVANAGERE – 577 002. 2. ASSESSMENT UNIT INCOME TAX DEPARTMENT REPRESENTED BY MINISTRY OF FINANCE GOVERNMENT OF INDIA NEW DELHI – 110 001. …RESPONDENTS (BY SRI Y.V.RAVIRAJ, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39713 WP No. 14784 of 2024 THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR IN THE NATURE OF WRIT OF CERTIORARI QUASHING THE NOTICES DATED 01-02-2023 ISSUED U/S 148A(B) OF THE ACT (ANNEXURE-A) ITBA/AST/F/148A(SCN)/2022-23/1049307538(1) ISSUED FOR THE ASSESSMENT YEAR 2016-17 BY THE 1 RESPONDENT; THE PETITIONER HUMBLY PRAY THIS HONBLE COURT MAY BE PLEASED TO ISSUE A WRIT OF CERTIORARI OR IN THE NATURE OF WRIT OF CERTIORARI QUASHING THE ORDER DATED 23.03.2023 MADE U/S 148A(D) OF THE ACT, FOR THE ASSESSMENT YEAR 2016-2017 (ANNEXURE-C) ITBA/AST/F/148A/2022-23/1051184055(1) PASSED BY THE 1ST RESPONDENT; THE PETITIONER HUMBLY PRAY THIS HONBLE COURT MAY BE PLEASED TO ISSUE A WRIT OF CERTIORARI OR IN THE NATURE OF WRIT OF CERTIORARI QUASHING THE NOTICE ISSUED U/S.148 OF THE ACT DATED 23-03-2023 FOR THE ASSESSMENT YEAR 2016-2017 (ANNEXURE-D) ITBA/AST/S/148_1/2022-23/1051185030 (1) ISSUED BY THE 1ST RESPONDENT. THE PETITIONER HUMBLY PRAY THIS HONBLE COURT MAY BE PLEASED TO ISSUE A WRIT OF CERTIORARI OR IN THE NATURE OF WRIT OF CERTIORARI QUASHING THE ORDER DATED 31.01.2024 MADE U/S 147 R.W.S.144 R.W.S 144B OF THE ACT, FOR THE ASSESSMENT YEAR 2016-2017 (ANNEXURE-F) (ITBA/AST/S/147/2023- 24/1060317169(1) PASSED BY THE 2ND RESPONDENT. - 3 - HC-KAR NC: 2025:KHC:39713 WP No. 14784 of 2024 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 - Assessee is before this Court seeking quashment of notices dated bearing No.ITBA/AST/F/148A(SCN)/2022-23/1049307538(1) dated 01.02.2023, ITBA/AST/S/148_1/2022-23/1051185030(1) dated 23.03.2023 and order No.ITBA/AST/F/148A/2022- 23/1051184055(1) dated 23.03.2023 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Rama Murthy R., 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 - HC-KAR NC: 2025:KHC:39713 WP No. 14784 of 2024 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 dated bearing No. ITBA/AST/F/148A(SCN)/2022-23/1049307538(1) dated 01.02.2023 and ITBA/AST/S/148_1/2022- 23/1051185030(1) dated 23.03.2023 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:39713 WP No. 14784 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.: 36 CT:SS