- 1 - HC-KAR NC: 2025:KHC:38897 WP No. 16114 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.16114 OF 2022 (T-IT) BETWEEN: SRI. MAHENDRA KARLE S/O SRI. LAKSHMEGOWDA THIMMEGOWDA KARLE AGED ABOUT 66 YEARS #151, INDUSTRTIAL SUBURB YESHWANTHPUR BENGALURU – 560 052 …PETITIONER (BY SRI. S. ANNAMALAI, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(3)(1) BANGALORE BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU - 560 095 Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:38897 WP No. 16114 of 2022 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-2 CENTRAL REVENUE BUILDING QUEENS ROAD, BENGALURU - 560 001 …RESPONDENTS (BY SRI. E. I. SANMATHI., ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO 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 15.03.2022 OF THE ACT FOR THE ASSESSMENT YEAR 2018-19 BY THE RESPONDENT NO.1 BEARING DIN & NOTICE NO.ITBA/AST/F/148A(SCN)/2021- 22/1040783919(1) HEREIN MARKED AS ANNEXURE-A1 AND ETC THIS PETITION COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:38897 WP No. 16114 of 2022 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 15.03.2022 of the Act for the assessment year 2018-19 by the Respondent No.1 bearing DIN & Notice No.ITBA/AST/F/148A(SCN)/2021-22/104078 3919(1) 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 30.03.2022 passed under section 148A(d) of the Act for the assessment year 2018-19 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/F/148A/2021-22/1042052455(1) herein marked as Annexure - A2. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 148 of the Act dated 30.03.2022 of the Act for the assessment year 2018-19 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/148_1/2021-22/1042116187(1) 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:38897 WP No. 16114 of 2022 2. Heard Sri S. Annamalai, 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 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 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. - 5 - HC-KAR NC: 2025:KHC:38897 WP No. 16114 of 2022 (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.: 284