- 1 - HC-KAR NC: 2025:KHC:39693 WP No. 24214 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. 24214 OF 2024 (T-IT) BETWEEN: CHANDRASHEKARAPPA PRABHAVATHI W/O SHRI M.CHANNAVEERAIAH AGED ABOUT 56 YEARS ANIKETANA, 3RD MAIN ROAD JAYANAGAR EAST TUMAKURU – 572 102. …PETITIONER (BY SRI RAVI SHANKAR S.V., ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD -1 AND TPS TUMAKURU AAYAKAR BHAVAN RAMAKRISHNANAGAR KUNIGAL ROAD TUMAKURU – 572 103. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX-2 BENGALURU BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39693 WP No. 24214 of 2024 BENGALURU – 560 095. 3. 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 E.I.SANMATHI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A) QUASHING THE UNSIGNED SANCTION DATED 26.03.2024 ACCORDED UNDER SECTION 151 OF THE ACT FOR THE ASSESSMENT YEAR 2020- 21 BY THE RESPONDENT NO. 2 BEARING DIN AND NOTICE NO. ITBA/AST/S/118/2023-24/1063393074(1) HEREIN MARKED AS ANNEXURE – A; B) QUASHING THE NOTICE DATED 27.03.2024 ISSUED UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT 2020-21 BY THE RESPONDENT NO. 1 BEARING DIN AND NOTICE NO. ITBA/AST/S/148_1/2023- 24/1063461837(1) HEREIN MARKED AS ANNEXURE - A1. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39693 WP No. 24214 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of DIN and notices bearing No.ITBA/AST/S/118/2023-24/1063393074(1) dated 26.03.2024 and ITBA/AST/S/148_1/2023-24/1063461837(1) dated 27.03.2024 issued by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Ravishankar S.V., 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 - 4 - HC-KAR NC: 2025:KHC:39693 WP No. 24214 of 2024 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned DIN and notices bearing No. ITBA/AST/S/118/2023-24/1063393074(1) dated 26.03.2024 and ITBA/AST/S/148_1/2023- 24/1063461837(1) dated 27.03.2024 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:39693 WP No. 24214 of 2024 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 2 Sl No.: 52