- 1 - HC-KAR NC: 2025:KHC:38577 WP No. 22532 of 2025 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.22532 OF 2025 (T-IT) BETWEEN: RAMACHANDRAPPA SARASWATHAMMA, W/O SRI. K. M. CHANDRAPPA, AGED ABOUT 53 YEARS, KALLUR VILLAGE, SUGATUR POST, KOLAR TALUK - 563 101, KOLAR DISTRICT. …PETITIONER (BY SRI. RAMA MURTHY R., ADVOCATE) AND: 1. THE INCOME TAX OFFICER, WARD 1, NEW EXTENSION, KOLAR - 563 101. 2. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, NEW DELHI - 110 001. …RESPONDENTS (BY SRI. E. I. SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR IN THE NATURE OF WRIT OF CERTIORARI QUASHING THE NOTICE DATED 25.01.2024 ISSUED U/S 148A(b) OF THE ACT (ANNEXURE-C) [ITBA/AST/F/148A(SCN)/2023-24/1060127965(1)] ISSUED FOR THE ASSESSMENT YEAR 2020-21 BY THE 1ST RESPONDENT AND ETC. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:38577 WP No. 22532 of 2025 THIS PETITION COMING ON FOR PRELIMINARY HEARING IN 'B' GROUP 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 prayers: “A. The Petitioner humbly pray this Hon’ble High Court may be pleased to issue a Writ of Certiorari or in the nature of Writ of Certiorari quashing: i. the Notice dated 25.01.2024 issued u/s 148A(b) of the Act (Annexure-C) [ITBA/AST/F/148A(SCN)/2023-24/1060127965(1)] issued for the assessment year 2020-21 by the 1st Respondent; ii. the order dated 25.03.2024 made u/s 148A(d) of the Act, for the assessment year 2020-21 (Annexure-E) [ITBA/AST/F/148A/2023- 24/1063320412(1)] passed by the 1st Respondent; iii. quashing the notice issued u/s.148 of the Act dated 25.03.2024 for the assessment year 2020-21 (Annexure-F) [ITBA/AST/S/148_1/2023- 24/1063321559(1)] issued by the 1st Respondent; iv. quashing the order dated 09.01.2025 made u/s 147 r.w.s. 144 r.w.s 144B of the Act, for the assessment year 2020-21 (Annexure-G) [ITBA/AST/S/147/2024-25/1072039991(1)] passed by the 2nd Respondent; v. quashing the order dated 01.07.2025 made u/s 272A(1)(d) of the Act, for the assessment year 2020-21 (Annexure-H) [ITBA/PNL/F/272A(1)(d) - 3 - HC-KAR NC: 2025:KHC:38577 WP No. 22532 of 2025 /2025-26/1078083714(1)] passed by the 2nd Respondent; vi. quashing the order dated 09.05.2024 made u/s 271AAC(1) of the Act, for the assessment year 2020-21 (ANNEXURE-H1) [ITBA/PNL/F/271AAC(1)/2025-26/1078083528(1)] passed by the 2nd Respondent; B. This Hon'ble High Court may be pleased to issue such other relief or reliefs as this Hon'ble Court deems fit, in the Petitioner's case, in the interest of justice.” 2. Heard Sri.Rama Murthy R, 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 petition deserves to be disposed on the same lines. Therefore, I pass the following: - 4 - HC-KAR NC: 2025:KHC:38577 WP No. 22532 of 2025 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. (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.: 1 Sl No.: 437