- 1 - HC-KAR NC: 2025:KHC:34196 WP No. 12505 of 2023 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. 12505 OF 2023 (T-IT) BETWEEN: 1. M/S.NARAYANA HRUDAYALAYA LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT,1956 REPRESETED BY ITS MANAGING DIRECTOR, SRI VIREN PRASAD SHETTY, SON OF SRI DEVI PRASAD SHETTY, AGED ABOUT 39 YEARS, NO.258/A, BOMMANSANDRA INDUSTRIAL AREA, BOMMASAMNDRA INDUSTRIAL ESTATE S.O. ALI, BOMMASANDRA, BENGALURU - 560 099. …PETITIONER (BY SRI. CHANDRASEKHAR V, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(2)(1), BANGALORE, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:34196 WP No. 12505 of 2023 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 QUASHING THE NOTICE DATED 13/04/2023 ISSUED UNDER SECTION 148A(B) OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE R1 BEARING DIN AND NOTICE NO ITBA/AST/F/148A(SCN)/2022-23/1051676054(1) HEREIN MARKED AS ANNEXURE -A1 AND QUASHING THE ORDER DATED 13/04/2023 PASSED UNDER SECTION 148A(D) OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE R1 BEARING DIN AND NOTICE NO ITA/AST/F/148A/2023-24/1052071939(1) HEREIN MARKED AS ANNEXURE-A2 AND ETC., THIS PETITION, COMING ON FOR PRELIMIANRY 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)/2022-23/1051676054(1) dated 13.04.2023, ITBA/AST/S/148_1/2023-24/1052072469(1) dated 13.04.2023 and order No.ITBA/AST/F/148A/2023- 24/1052071939(1) dated 13.04.2023 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. - 3 - HC-KAR NC: 2025:KHC:34196 WP No. 12505 of 2023 2. Heard Sri Chandrasekhar V., learned counsel for the petitioner and Sri E.I.Sanmathi, 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 notices bearing No. ITBA/AST/F/148A(SCN)/2022-23/1051676054(1) dated 13.04.2023, ITBA/AST/S/148_1/2023- 24/1052072469(1) dated 13.04.2023 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. - 4 - HC-KAR NC: 2025:KHC:34196 WP No. 12505 of 2023 (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 NVJ List No.: 1 Sl No.: 342 ct.sm