- 1 - HC-KAR NC: 2025:KHC:39695 WP No. 25948 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. 25948 OF 2024 (T-IT) BETWEEN: NANDISH DOMMALLUR S/O SHIVANNA LINGAIAH DOMMALLUR, AGED ABOUT 64 YEARS, R/AT: C-12, NO. 156 EPSILON, VENTURES VILLA LAYOUT, AMMANI BELANDUR, MARATHAHALLI, BENGALURU – 560 037. PAN NO. AAZPN5719J. …PETITIONER (BY SRI BALRAM R. RAO, ADVOCATE) AND: 1. INCOME TAX DEPARTMENT OFFICE OF THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCE 1(2) CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU – 560 001. 2. INCOME TAX DEPARTMENT OFFICE OF THE DIRECTOR, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39695 WP No. 25948 of 2024 GENERAL OF INCOME TAX, INVESTIGATION DGIT. (INVESTIGATION) CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU. …RESPONDENTS (BY SRI M.DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO CALLING FOR THE RECORDS OF THE PETITIONER’S CASE AND AFTER EXAMINING THE LEGALITY AND VALIDITY THEREOF BE PLEASED TO QUASH AND SET ASIDE THE IMPUGNED NOTICE PASSED UNDER CLAUSE (b) OF SECTION 148A OF THE ACT DTD 07.08.2024 IN DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2023- 24/1067414511(1) [ANNEXURE-A] AS WELL AS IMPUGNED ORDER PASSED UNDER SECTION 148A(d) OF THE ACT DTD 23.08.2024 IN DIN AND ORDER NO. ITBA/AST/F/148A/2024- 25/1067920251(1) [ANNEXURE-D] AS WELL AS NOTICE DTD 23.08.2024 ISSUED UNDER SECTION 148 OF THE ACT IN DIN AND NOTICE NO. ITBA/AST/S/148_1/2024-25/1067921365(1) [ANNEXURE-E] PASSED BY THE R-1 FOR THE AY 2018-19 AND RESTRAINING THE RESPONDENTS BY THEMSELVES THEIR SUBORDINATE, SERVANTS AND AGENTS FROM TAKING ANY ACTION IN FURTHERANCE OR CONSEQUENT IMPUGNED NOTICE PASSED UNDER CLAUSE (b) OF SECTION 148A OF THE ACT DTD 07.08.2024 IN DIN AND NOTICE NO. ITBA/AST/F/148A(SCN) 2023-24/1067414511(1)(ANNEXURE- - 3 - HC-KAR NC: 2025:KHC:39695 WP No. 25948 of 2024 A) AS WELL AS IMPUGNED ORDER PASSED UNDER SECTION 148A(d) OF THE ACT DTD 23.08.2024 IN DIN AND ORDER NO. ITBA/AST/F/148A/2024-25/1067920251(1) [ANNEXURE-D] AS WELL AS NOTICE DTD 23.08.2024 ISSUED U/S 148 OF THE ACT IN DIN AND NOTICE NO.ITBA/AST/S/148_1/2024- 25/1067921365(1) [ANNEXURE-E] PASSED BY THE R-1 FOR THE AY 2018-19. 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 - Assessee is before this Court seeking quashment of DIN and notices bearing No.ITBA/AST/F/148A(SCN) /2023-24/1067414511(1) dated 07.08.2024, ITBA/AST/S/148_1/2024-25/1067921365(1) dated 23.08.2024 and order bearing No.ITBA/AST/F/148A/2024-25/1067920251(1) dated 23.08.2024 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. - 4 - HC-KAR NC: 2025:KHC:39695 WP No. 25948 of 2024 2. Heard Sri Balaram R. Rao, learned counsel for the petitioner and Sri M. Dilip, learned counsel for 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 DIN and notices bearing No. ITBA/AST/F/148A(SCN) /2023-24/1067414511(1) dated 07.08.2024, ITBA/AST/S/148_1/2024- 25/1067921365(1) dated 23.08.2024 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 - 5 - HC-KAR NC: 2025:KHC:39695 WP No. 25948 of 2024 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 becomes necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 2 Sl No.: 54