- 1 - HC-KAR NC: 2025:KHC:39426 WP No. 25330 of 2022 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. 25330 OF 2022 (T-IT) BETWEEN: RAMESH S/O SRI H.J.RAMAIAH AGED ABOUT 45 YEARS R/AT NO. 13, K.NO. 86/2 7TH CROSS, 11TH MAIN SRINIVASA LAYOUT NEW MSR LAYOUT HONGASANDRA BENGALURU - 560 068 PAN:AHYPR0935N …PETITIONER (BY SRI ANNAMALAI S., ADVOCATE) AND: 1. CENTRAL BOARD OF DIRECT TAXES DEPARTMENT OF REVENUE MINISTRY OF FINANCE NORTH BLOCK NEW DELHI – 110 002 REPRESENTED HEREIN BY ITS CHAIRPERSON. 2. NATIONAL FACELESS ASSESSMENT CENTRE REPRESENTED BY ADDITIONAL / JOINT/ DEPUTY/ ASSISTANT COMMISSIONER OF INCOME TAX Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39426 WP No. 25330 of 2022 INCOME-TAX OFIFCER INCOME-TAX DEPARTMENT MINISTRY OF FINANCE ROOM NO.401, 2ND FLOOR E-RAMP, JAWAHARLAL NERHU STADIUM DELHI – 110 003. 3. THE INCOME TAX OFFICER WARD 4(3)(2), BENGALURU ROOM 415, 4TH FLOOR BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, KORAMANGALA BENGALURU – 560 095. 4. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME-TAX KARNATAKA AND GOA REGION C.R.BUILDING, II FLOOR QUEENS ROAD, BENGALURU – 560 001. …RESPONDENTS (BY SRI Y.V.RAVIRAJ AND M.DILIP, ADVOCATES) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUION OF INDIA PRAYING TO QUASHING THE NOTICE ISSUED UNDER SECTION 148A(b) OF THE ACT DATED 20.05.2022 BEARING DIN AND LETTER NO. ITBA/COM/F/17/2022 BEARING DIN AND LETTER NO. ITBA/ COM/F/17/2022-23/1043097122(1) ISSUED BY THE RESPONDENT NO. 3 FOR THE ASSESSMENT YEAR 2014-15 HEREIN MARKED AS ANNEXURE-A1 AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39426 WP No. 25330 of 2022 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/COM/F/17/2022- 23/1043097122(1) dated 20.05.2022, ITBA/AST/M/148_1/2022-23/1044319271(1) dated 29.07.2022, ITBA/AST/S/148/2021-22/1032454780(1) dated 16.04.2021, instruction bearing No.1/2022 dated 11.05.2022 and order No.ITBA/COM/F/17/2022-23/1044297269(1) dated 29.07.2022 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri Y.V.Raviraj 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 - HC-KAR NC: 2025:KHC:39426 WP No. 25330 of 2022 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/COM/F/17/2022-23/1043097122(1) dated 20.05.2022, ITBA/AST/M/148_1/2022- 23/1044319271(1) dated 29.07.2022, ITBA/AST/S/148/2021-22/1032454780(1) dated 16.04.2021 and instruction bearing No.1/2022 dated 11.05.2022 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:39426 WP No. 25330 of 2022 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 317 CT:SS