- 1 - HC-KAR NC: 2025:KHC:36526 WP No. 23328 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. 23328 OF 2023 (T-IT) BETWEEN: RAMESH SHARMA S/O SRI.T.R. SHARMA, AGED ABOUT 40 YEARS, PROP. GOMTI INCINCO, NO.3B-2, KIADB INDUSTRIAL AREA, IST PHASE, KUMBALAGODU, MYSURU ROAD, BENGALURU-560 074. PRESENTLY RESIDING AT NO.53, 8TH CROSS, JAIMUNIRAO CIRCLE, AGRAHARA DASARAHALLI, BENGALURU-560 079. …PETITIONER (BY SRI. SHREEHARI, ADVOCATE) AND: 1. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 3(1) (1), BENGALURU, BMTC BUILDING, 80FT ROAD, 6TH BLOCK, KORAMANGALA, BENGALURU-560 095. THE ASSESSING OFFICER UNDER THE INCOME TAX ACT, 1961, Digitally signed by NAGAVENI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:36526 WP No. 23328 of 2023 2. PRINCIPAL COMMISSIONER OF INCOME TAX BENGALURU-3 THE APPROVING AUTHORITY UNDER THE SECTION 151 OF THE INCOME TAX ACT, 1961, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU-560 095. 3. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC) A CENTRE DESCRIBED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961, ROOM NO.401, 2ND FLOOR, E- RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110 003. REPRESENTED BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC) …RESPONDENTS (BY SRI. SUSHAL TIWARI, ADVOCATE) THIS WP IS FILED UNDER ARTICLE 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO QUASH THE NOTICE U/S 148A(b) OF THE INCOME TAX ACT, 1961 DTD 15.03.2022 ISSUED BY THE R1 WHICH BEARS THE DIN - ITBA/AST/F/ 148A(SCN)/2021-22/1040738535(1) AND ENCLOSED AS ANNEXURE-B AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:36526 WP No. 23328 of 2023 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)/2021-22/1040738535(1) dated 15.03.2022, ITBA/AST/S/148_1/2021-22/1042398833(1) dated 31.03.2022, ITBA/AST/S/156/2022-23/1051580655(1) dated 29.03.2023, ITBA/PNL/S/156/2023-24/1056586371(1) dated 27.09.2023, ITBA/PNL/S/156/2023-24/1056544038(1) dated 26.09.2023 and order Nos.ITBA/AST/F/148A/2021- 22/1042394621(1) dated 31.03.2022, dated 23.11.2023, ITBA/AST/S/147/2022-23/1051580064(1) dated 29.03.2023, DIN No.ITBA/PNL/F/270A/2023-24/1056586499(1) dated 27.09.2023, ITBA/PNL/F/272A(1)(d)/2023-24/1056544361(1) dated 26.09.2023, ITBA/PNL/F/271AAC(1)/2023- 24/1056598155(1) dated 27.09.2023 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Shreehari, learned counsel for the petitioner and Sri Sushal Tiwari, learned counsel for the respondents. - 4 - HC-KAR NC: 2025:KHC:36526 WP No. 23328 of 2023 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)/2021-22/1040738535(1) dated 15.03.2022, ITBA/AST/S/148_1/2021- 22/1042398833(1) dated 31.03.2022, ITBA/AST/S/156/2022-23/1051580655(1) dated 29.03.2023, ITBA/PNL/S/156/2023- 24/1056586371(1) dated 27.09.2023, ITBA/PNL/S/156/2023-24/1056544038(1) dated 26.09.2023 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. - 5 - HC-KAR NC: 2025:KHC:36526 WP No. 23328 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.: 355