- 1 - HC-KAR NC: 2025:KHC:39450 WP No. 9103 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. 9103 OF 2023 (T-IT) BETWEEN: PALLASANNA KRISHNA SUBRAMANIAN AGED ABOUT 81 YEARS RESIDING AT VILLA NO.492 ADARSH PALM RETREAT OUTER RING ROAD BENGALURU – 560 103 HAVING PAN NO. AQAPS8423P. …PETITIONER (BY MS. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 4(1) (1) BMTC BUILDING 80 FEET ROAD, KORAMANGALA BENGALURU - 560 095. 2. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX 5TH FLOOR, BMTC BUILDING, 6TH BLOCK 80 FEET ROAD, KORAMANGALA Digitally signed by NAGAVENI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:39450 WP No. 9103 of 2023 BENGALURU - 560 095. 3. UNION OF INDIA REPRESENTED HEREIN BY THE FINANCE SECRETARY MINISTRY OF FINANCE DEPARTMENT OF REVENUE GOVERNMENT OF INDIA NORTH BLOCK NEW DELHI - 110 001. …RESPONDENTS (BY SRI E.I.SANMATHI, ADVOCATE) THIS WP FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ORDER DTD.06.04.2023 BEARING NO. ITBA/AST/F/148A/2023- 24/1051923517(1) ANNX-F PASSED BY THE R1 U/S 148A(D) OF THE ACT, REJECTING THE PETITIONERS OBJECTION AS TO THE INITIATION OF THE PROCEEDINGS FOR AY.2016-17; QUASH THE NOTICE DT.06.04.2023 BEARING NO. ITBA/AST/S/148_1/2023-24/1051923616(1) ISSUED BY THE R1 (ANNX-G) TO THE PETITIONER U/S 148 OF THE ACT FOR THE AY. 2016-17. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39450 WP No. 9103 of 2023 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notice bearing No.ITBA/AST/S/148_1/2023- 24/1051923616(1) dated 06.04.2023 and order No.ITBA/AST/F/148A/2023-24/1051923517(1) dated 06.04.2023 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Ms. Tanmayee Rajkumar, 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 - 4 - HC-KAR NC: 2025:KHC:39450 WP No. 9103 of 2023 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned notice bearing No. ITBA/AST/S/148_1/2023-24/1051923616(1) dated 06.04.2023 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. (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 - 5 - HC-KAR NC: 2025:KHC:39450 WP No. 9103 of 2023 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 332 CT:SS