- 1 - HC-KAR NC: 2025:KHC:39272 WP No. 23371 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. 23371 OF 2025 (T-IT) BETWEEN: 1. SMT. SUNITHA BHATNAGAR WIFE OF SRI. DEEPAK BHATNAGAR, AGED ABOUT 50 YEARS, 21-5, 2ND FLOOR, 3RD MAIN, KHM BLOCK, GANGANAGAR, BANGALORE - 560 032. PAN: AJYPP4932B. …PETITIONER (BY SRI. ANNAMALAI S., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER/ ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 6(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560 095. 2. THE JOINT / ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 6(1), BMTC BUILDING, 80 FEET ROAD, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39272 WP No. 23371 of 2025 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560 095. …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO I) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE ISSUED UNDER SECTION 148A(1) OF THE ACT DATED 22/03/2025 BEARING DIN AND NOTICE NO.ITBA/AST/F/148A(SCN)-1/2024-25/1074863138(1) ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2019-20 HEREIN MARKED AS ANNEXURE-A1. II) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE ORDER DATED 29/06/2025 PASSED UNDER SECTION 148A(3) OF THE ACT BEARING DIN AND NOTICE NO. ITBA/AST/F/148A/2025- 26/1077989611(1) ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2019-20 HEREIN MARKED AS ANNEXURE-A2. III) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE DATED 29/06/2025 ISSUED UNDER SECTION 148 OF THE ACT BEARING DIN AND NOTICE NO. ITBA/AST/S/148-1/2025-26/1077989722(1) ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2019-20 HEREIN MARKED AS ANNEXURE-A3. - 3 - HC-KAR NC: 2025:KHC:39272 WP No. 23371 of 2025 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(1) of the Act dated 22/03/2025 bearing DIN & Notice No. ITBA/AST/F/148A(SCN)_1/2024- 25/1074863138(1) issued by the Respondent No. 1 for the assessment year 2019-20 herein marked as Annexure A1. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 29/06/2025 passed under section 148A(3) of the Act bearing DIN & Notice No. ITBA/AST/F/148A/2025-26/1077989611(1) issued by the Respondent No. 1 for the assessment year 2019-20 herein marked as Annexure - A2. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 29/06/2025 issued under section 148 of the Act bearing DIN & Notice No. ITBA/AST/S/148_1/2025-26/1077989722(1) issued by the Respondent No. 1 for the assessment year 2019- 20 herein marked as Annexure A3. iv) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." - 4 - HC-KAR NC: 2025:KHC:39272 WP No. 23371 of 2025 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri M. Dilip, 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 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. - 5 - HC-KAR NC: 2025:KHC:39272 WP No. 23371 of 2025 (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 SJK CT-SG List No.: 2 Sl No.: 94