- 1 - HC-KAR NC: 2025:KHC:34867 WP No. 16417 of 2024 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. 16417 OF 2024 (T-IT) BETWEEN: 1. M/S SV AND SONS REPRESENTED BY ITS PARTNER, SRI K N MURALI, S/O SRI NARAYANAPPA, AGED ABOUT 41 YEARS, NO. 83/2, 3RD MAIN, APMC YARD, YESHWANTHPUR, BENGALURU - 560 022. PRESENTLY AT DOOR No. 27 KUPPASWAMY MUDALIYAR LAYOUT, BANGARAPET - 563 114 PAN ABPFS2908D. …PETITIONER (BY SRI. ANNAMALAI S, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD 6(2)(1) BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 2. THE CHIEF COMMISSIONER OF INCOME TAX, BENGALURU-1 CR BUILDINGS, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:34867 WP No. 16417 of 2024 NO. 1 QUEENS ROAD, BENGALURU - 560 001. …RESPONDENTS (BY SRI SUSHAL TIWARI, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE ISSUED UNDER SECTION 148A(b) OF THE ACT DTD. 30.03.2024 BEARING DIN AND LETTER NO. ITBA/AST/F/148A(SCN)/2023-24/1063733318(1) ISSUED BY THE R-1 FOR THE ASSESSMENT YEAR 2017-18 HEREIN MARKED AS ANNX-A1 AND QUASH THE NOTICE ISSUED UNDER SECTION 148A(b) OF THE ACT DTD. 08.04.2024 BEARING DIN AND LETTER NO. ITBA/AST/F/148A(SCN)/2024- 25/1063976648(1) ISSUED BY THE R-1 FOR THE ASSESSMENT YEAR 2017-18 HEREIN MARKED AS ANNX-A2 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: “i) 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 30/03/2024 bearing DIN & Letter No. ITBA/AST/F/148A(SCN)/2023-24/1063733318(1) issued by the Respondent No.1 for the assessment year 2017-18 herein marked as Annexure - A1. ii) 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 08/04/2024 - 3 - HC-KAR NC: 2025:KHC:34867 WP No. 16417 of 2024 bearing DIN & Letter No. ITBA/AST/F/148A(SCN)/2024-25/1063976648(1) issued by the Respondent No.1 for the assessment year 2017-18 herein marked as Annexure - A2. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 16/04/2024 passed under section 148A(d) of the Act bearing DIN & Order No. ITBA/AST/F/148A/2024-25/1064140326(1) by the Respondent No. 1 for the assessment year 2017-18 herein marked as Annexure - АЗ. iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 16/04/2024 issued under section 148 of the Act bearing DIN & Notice No. ITBA/AST/S/148_1/2024- 25/1064141991(1) issued by the Respondent No. 1 for the assessment year 2017-18 herein marked as Annexure - A4. v) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri Sushal Tiwari, 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:34867 WP No. 16417 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 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. (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.: 379/CT.SM