- 1 - HC-KAR NC: 2025:KHC:36470 WP No. 12261 of 2024 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.12261 OF 2024 (T-IT) BETWEEN: M/S. IBC DATTAGIRI ESTATE A PARTNERSHIP FIRM REGISTERED UNDER THE IDNIAN PARTNERSHIP ACT 1932, REPRESENTED BY ITS PARTNER, SRI ZIAULLA SHARIFF SON OF SRI ABDUL GAFFAR SHERIFF, AGED ABOUT 84 YEARS, TOWER B 9TH FLOOR DIAMOND DISTRICT, OLD AIRPORT ROAD, BENGALURU 560 008. …PETITIONER (BY SRI. MADHUSUDHAN U. A., ADVOCATE) AND: 1. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE HASSAN, AAYAKAR BHAVAN, 2ND STAGE, BELUR ROAD, HASSAN 573 201. 2. THE EPRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) PANAJI, RIGHT WINGS, TRISTAR BUILDING, EDC COMPLEX, PATTO, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:36470 WP No. 12261 of 2024 PANAJI 403 001. …RESPONDENTS (BY SRI. Y.V.RAVI RAJ AND SRI M.DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO A) QUASH THE NOTICE DATED 27/10/2023 ISSUED UNDER SECTION 148 OF THE INCOME TAX ACT, 1961, ISSUED BY THE R1, FOR THE ASSESSMENT YEAR 2020-21, BEARING DIN AND LETTER NO. ITBA/COM/F/17/2023-24/1057464553(1) HEREIN MARKED AS ANNEXURE-A AND ETC. 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: “a) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 27.10.2023 issued under section 148 of the Income Tax Act, 1961, issued by the Respondent No.1, for the assessment year 2020-21, bearing DIN & Letter No. ITBA/COM/F/17/2023- 24/1057464553(1) herein marked as Annexure - A. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order disposal - 3 - HC-KAR NC: 2025:KHC:36470 WP No. 12261 of 2024 of objections to notice issued under section 148 of the Income Tax Act, 1961 dated 28.02.2024 passed by the Respondent No.1, for the assessment year 2020-21, bearing DIN & Letter No. ITBA/AST/F/17/2023-24/1061644272(1) herein marked as Annexure - B. c) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri Madhusudhan U.A., learned counsel for the petitioner and Sri Y.V.Ravi Raj 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 - 4 - HC-KAR NC: 2025:KHC:36470 WP No. 12261 of 2024 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 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 372