- 1 - HC-KAR NC: 2025:KHC:39203 WP No. 8212 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. 8212 OF 2024 (T-IT) BETWEEN: MIR. MOHAMMED RAZA, S/O MIR MAHADI HUSSAIN, AGED ABOUT 45 YEARS, NO. 26/1, ALFRED STREET, RICHMOND TOWN, BANGALORE - 560 025. …PETITIONER (BY SRI. RAMA MURTHY R, ADVOCATE) AND: 1. THE INCOME TAX OFFICER, WARD - 4(1), HYDERABAD - 500004. 2. ASSESSMENT UNIT INCOME TAX DEPARTMENT, NEW DELHI - 110 001. …RESPONDENTS (BY SRI.M.DILIP, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39203 WP No. 8212 of 2024 THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ORDER MADE U/S 148A(d) OF THE ACT DATED 12/04/2022 IN DIN ITBA/AST/F/148A/2022-23/1042720724(1) MADE FOR THE ASSESSMENT YEAR 2015-2016 (ANNEXURE-B) MADE BY THE RESPONDENT ON THE GROUND OF LIMITATION AND VIOLATION OF PRINCIPLES OF NATURAL JUSTICE; QUASH THE NOTICE ISSUED U/S 148 OF THE ACT DATED 12/04/2022 FOR THE ASSESSMENT YEAR 2015-16 (ANNEXURE-C) IN DIN ITBA/AST/S/148_1/2022-23/1042720778(1) ISSUED BY THE RESPONDENT ON THE GROUND OF LIMITATION AND JURISDICTION; QUASH THE ORDER DATED 24.11.2023 MADE U/S 147 R.W.S. 144 R.W.S 144B OF THE ACT IN DIN ITBA/AST/S/147/2023-24/1058248985(1), FOR THE ASSESSMENT YEAR 2015-2016 (ANNEXURE - 'D') ISSUED BY THE RESPONDENT ON THE GROUND OF WITHOUT JURISDICTION AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39203 WP No. 8212 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “A. The Petitioner humbly pray this Hon'ble Court may be pleased to issue a Writ of Certiorari or in the nature of Writ of Certiorari quashing the order made u/s.148A(d) of the Act dated 12.04.2022 in DIN ITBA/AST/F/148A/2022-23/1042720724(1) made for the assessment year 2015-2016 (Annexure - 'B') made by the Respondent on the ground of limitation and violation of principles of natural justice and B. The Petitioner humbly pray this Hon'ble Court may be pleased to issue a Writ of Certiorari or in the nature of Writ of Certiorari quashing the notice issued u/s.148 of the Act dated 12.04.2022 for the assessment year 2015- 2016 (Annexure - 'C') in DIN ITBA/AST/S/148_1/2022- 23/1042720778(1) issued by the Respondent on the ground of limitation and jurisdiction. C. The Petitioner humbly pray this Hon'ble Court may be pleased to issue a Writ of Certiorari or in the nature of Writ of Certiorari quashing the order dated 24.11.2023 made u/s 147 r.w.s. 144 r.w.s 144B of the Act in DIN ITBA/AST/S/147/2023-24/1058248985(1), for the assessment year 2015-2016 (Annexure - 'D') issued by the Respondent on the ground of without jurisdiction; D. This Hon'ble Court may be pleased to issue such other relief or reliefs as this Hon'ble Court deems fit, in the interest of justice, in the Petitioner's case.” - 4 - HC-KAR NC: 2025:KHC:39203 WP No. 8212 of 2024 2. Heard Sri.Rama Murthy R, learned counsel for the petitioner 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 Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in this petition would stand quashed. - 5 - HC-KAR NC: 2025:KHC:39203 WP No. 8212 of 2024 (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 CBC List No.: 2 Sl No.: 18