- 1 - HC-KAR NC: 2025:KHC:35153 WP No. 7751 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. 7751 OF 2025 (T-RES) BETWEEN: BHANWARLAL JAIN SAPNA, AGED 41 YEARS, No.15, 2ND FLOOR, GURUSIDDAPPA BLDG, OPP. JAIN TEMPLE, 4TH MAIN GANDHI NAGAR, BANGALORE, BENGALURU URBAN, KARNATAKA - 560 009. …PETITIONER (BY SRI. BHARATH KUMAR V, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1) - BANGALORE BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU - 560 095. 2. CHIEF COMMISSIONER OF INCOME TAX BMTC BUILDING, 80 FT ROAD, KORAMANGALA, BENGALURU -560 095. 3. INCOME TAX OFFICER, WARD 5(2)(1) BANGALORE, BMTC BUILDING, 80 FT. ROAD KORAMANGALA, BENGALURU -560 095. …RESPONDENTS (BY SRI Y V RAVI RAJ AND SRI M DILIP, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ORDER Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:35153 WP No. 7751 of 2025 DTD. 09.03.2024 BEARING NO. ITBA/AST/F/148A(SCN)/2023- 24/1062314066(1) (ANNX-B) PASSED BY THE R-1 UNDER SECTION 148A OF THE ACT FOR THE ASSESSMENT YEAR 2020- 21 AND QUASH THE ORDER DTD. 28.03.2024 BEARING NO. ITBA/AST/S/148/2023-24/1063559803 (ANNX-D) PASSED BY THE R-1 UNDER SECTION 148A(d) OF THE ACT FOR THE ASSESSMENT YEAR 2020-21 AND ETC., THIS PETITION, COMING ON FOR ORDERS 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 notices bearing No. ITBA/AST/F/148A(SCN)/2023-24/1062314066(1) dated 09.03.2024, ITBA/AST/S/148_1/2023-24/1063559803(1) dated 28.03.2024, ITBA/AST/S/156/2024-25/1074308203(1) dated 10.03.2025, ITBA/PNL/S/271AAC(1)/2024- 25/1074308195(1) dated 10.03.2025 and order of assessment No.ITBA/AST/S/147/2024-25/1074308139(1) dated 10.03.2025 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. - 3 - HC-KAR NC: 2025:KHC:35153 WP No. 7751 of 2025 2. Heard Sri Bharath Kumar V., learned counsel for the petitioner and Sri Y.V.Raviraj 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 notices bearing No. ITBA/AST/F/148A(SCN)/2023-24/1062314066(1) dated 09.03.2024, ITBA/AST/S/148_1/2023- 24/1063559803(1) dated 28.03.2024, ITBA/AST/S/156/2024-25/1074308203(1) dated 10.03.2025, ITBA/PNL/S/271AAC(1)/2024- 25/1074308195(1) dated 10.03.2025 issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All - 4 - HC-KAR NC: 2025:KHC:35153 WP No. 7751 of 2025 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 NVJ List No.: 1 Sl No.: 417