- 1 - HC-KAR NC: 2025:KHC:39298 WP No. 4935 of 2025 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. 4935 OF 2025 (T-IT) BETWEEN: E THIMMASANDRA VVYAVASAYA SEVA SAHAKARA SANGHA LTD., E THIMMASANDRA SHIDLAGHATTA, CHIKKABALLAPURA - 562 105, REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER, SHRI. AKKALAPPA.M.S., (UNDER REGISTERED KARNATAKA CO-OPERATIVE SOCIETIES ACT, 1959) …PETITIONER (BY SMT. LOCHANA S. BABU, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD-1, CHIKKABALLAPURA, YASHODA COMPLEX, B.B.ROAD, CHIKKABALLAPURA - 562 101. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU-1, CENTRAL REVENUE BUILDING, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39298 WP No. 4935 of 2025 QUEENS ROAD, BENGALURU - 560 001. 3. ASSESSMENT UNIT NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWARLAL NEHRU STADIUM, DELHI - 110 003. …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A) QUASHING THE NOTICE ISSUED UNDER SECTION 148A(B) OF THE INCOME TAX ACT, 1961 (HEREINAFTER REFERRED TO AS THE ACT) DATED 02.02.2023 FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO. 1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2022-23/1049352579(1) HEREIN MARKED AS ANNEXURE - A1 AND ETC., - 3 - HC-KAR NC: 2025:KHC:39298 WP No. 4935 of 2025 THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN 'B' GROUP, 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 prayers: “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 Income Tax Act, 1961 (hereinafter referred to as "the Act") dated 02.02.2023 for the assessment year 2019-20 by the Respondent No. 1 bearing DIN & Notice no. ITBA/AST/F/148A(SCN)/2022- 23/1049352579(1) herein marked as Annexure - A1. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Notice issued under section 148A(b) dated 17.02.2023 for the Assessment year 2019-20 by the Respondent No. 1 bearing DIN & No. Notice ITBA/AST/F/148A(SCN)/2022- 23/1049877936(1) herein marked as Annexure - A2. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Order passed under section 148A(d) of the Act dated 18.03.2023 by the Respondent No. 1 for the Assessment year 2019-20 bearing DIN & - 4 - HC-KAR NC: 2025:KHC:39298 WP No. 4935 of 2025 Notice No. ITBA/AST/F/148A/2022- 23/1050933869(1) herein marked as Annexure -A3. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Notice issued under section 148 of the Act dated 18.03.2023 by the Respondent No. 1 for the assessment year 2019-20 bearing DIN & Notice No. ITBA/AST/S/148_1/2022- 23/1050937336(1) herein marked as Annexure -A4. e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the assessment order passed under section 147 r.w.s 144 r.w.s 144B of the Act dated 20.01.2024 passed by the Respondent No. 3 bearing DIN & Notice No. ITBA/AST/S/147/2023-24/1059957059(1) herein marked as Annexure - A5. h) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 270A of the Act dated 20.01.2024 bearing DIN & Notice No. ITBA/PNL/S/270A/2023-24/1059957082(1) issued by the Respondent No. 3 herein marked as Annexure - B1. i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Order passed under section 270A of the Act dated 11.07.2024 bearing DIN & Notice No. ITBA/PNL/F/270A/2024-25/1066641928(1) passed by the Respondent No. 3 herein marked as Annexure - B2. j) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 271AAC(1) of the - 5 - HC-KAR NC: 2025:KHC:39298 WP No. 4935 of 2025 Act dated 20.01.2024 bearing DIN & Notice No. ITBA/PNL/S/271AAC(1)/2023- 24/1059957083(1) issued by the Respondent No. 3 herein marked as Annexure - B3. k) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing Order passed under section 271AAC(1) of the Act dated 25.07.2024 passed by the Respondent No. 3 bearing DIN & Notice No. ITBA/PNL/F/271AAC(1)/2024- 25/1067010924(1) herein marked as Annexure - B4. l) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 272A(1) (d) of the Act dated 18.01.2024 bearing DIN & Notice No. ITBA/PNL/S/272A(1)(d)_FL/2023- 24/1059876310(1) issued by the Respondent No. 3 herein marked as Annexure- B5. m) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing Order passed under section 272A(1)(d) of the Act dated 18.07.2024 passed by the Respondent No. 3 bearing DIN & Notice No. ITBA/PNL/F/272A(10(d)/2024- 25/1066824419(1) herein marked as Annexure - B6. n) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Smt. Lochana S. Babu., learned counsel appearing for the petitioner and Shri M. Dilip, learned counsel appearing for the respondents. - 6 - HC-KAR NC: 2025:KHC:39298 WP No. 4935 of 2025 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 notice issued by the jurisdictional Assessing Officer outside the scope of Section 151-A 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. - 7 - HC-KAR NC: 2025:KHC:39298 WP No. 4935 of 2025 (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 JY List No.: 2 Sl No.: 73 CT:BHK