- 1 - HC-KAR NC: 2025:KHC:39254 WP No. 25324 of 2024 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. 25324 OF 2024 (T-IT) BETWEEN: 1. C.B.C.I. SOCIETY FOR MEDICAL EDUCATION ST. JOHNS MEDICAL COLLEGE CAMPUS, SARJAPUR ROAD, JOHNANAGAR, KORMANGALA, BANGALORE - 560 034, KARNATAKA (REPRESNTED BY ITS DIRECTOR MR. JESUDOSS RAJAMANICKAM, S/O RAJAMANICKAM, AGED ABOUT 55 YEARS) REGISTERED SOCIETY UNDER MYSORE SOCIETIES REGISTRATION ACT, 1960. …PETITIONER (BY SMT. GEETHA RANI K., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX EXEMPTIONS CIRCLE -1, UNITY BUILDING ANNEXE, MISSION ROAD, BENGALURU - 560 027. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39254 WP No. 25324 of 2024 2. THE ADDITIONAL/JOINT/DEPUTY ASSISTANT COMMISSIONER OF INCOME TAX, INCOME-TAX OFFICER, NATIONAL FACELESS-ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO. 401, 2ND FLOOR, E RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003. …RESPONDENTS (BY SRI. ARAVIND V. CHAVAN, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH AS FAR AS THE PETITIONER IS CONCERNED BY AN APPROPRIATE WRIT OR ORDER IN THE NATURE OF CERTIORARI OR OTHERWISE THE IMPUGNED ORDER UNDER SECTION 148A(D) OF THE ACT VIDE ITBA/AST/F/148A/2023-24/1062869299(1) DATED 18.03.2024 PASSED BY THE LEARNED FIRST RESPONDENT FOR AY 2017-18 ENCLOSED AS ANNX-A AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39254 WP No. 25324 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court, seeking the following prayer: "A. Quash as far as the Petitioner is concerned by an appropriate writ or order in the nature of Certiorari or otherwise the Impugned Order under section 148A(d) of the Act vide ITBA/AST/F/148A/2023- 24/1062869299(1) dated 18.03.2024 passed by the Learned First Respondent for AY 2017-18, enclosed as Annexure A. B. Quash as far as the Petitioner is concerned by an appropriate writ or order in the nature of Certiorari or otherwise the impugned Notice under section 148 of the Act vide ITBA/AST/S/148_1/2023- 24/1062870009(1) dated 18.03.2024 issued by the Learned First Respondent for AY 2017-18, enclosed as Annexure B. C. Grant such other reliefs as this Honourable High Court may think fit including the cost of this writ petition." 2. Heard Smt. Geetha Rani K., learned counsel for the petitioner and Sri Aravid V. Chavan, learned counsel for the respondents. - 4 - HC-KAR NC: 2025:KHC:39254 WP No. 25324 of 2024 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. (iii) With the aforesaid liberty and to the aforesaid extent, the petition is allowed. - 5 - HC-KAR NC: 2025:KHC:39254 WP No. 25324 of 2024 (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.: 5 Sl No.: 14