- 1 - HC-KAR NC: 2025:KHC:39452 WP No. 9132 of 2023 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. 9132 OF 2023 (T-IT) BETWEEN: SRI SOHANLAL S/O SRI PREMCHAND AGED ABOUT 43 YEARS PROP. BHANSALI TRADERS NO.10/1, BUNDIMUTT ROAD AVENUE ROAD CROSS BENGALURU - 560 002. ALSO AT: NO.3A, 3RD FLOOR, NO.51 PUSHPA VALIKA, VANI VILAS ROAD BASAVANAGUDI BENGALURU – 04. …PETITIONER (BY SRI ANNAMALAI S., ADVOCATE) AND: 1. ASSESSMENT UNIT INCOME TAX DEPARTMENT NATIONAL FACELESS ASSESSMENT CENTRE REP. BY ADDITIONAL/JOINT/DEPUTY/ ASSISTANT COMMISSIONER OF INCOME-TAX/ INCOME-TAX OFFICER MINISTRY OF FINANCE ROOM NO.401, 2ND FLOOR, E-RAMP Digitally signed by NAGAVENI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:39452 WP No. 9132 of 2023 JAWAHARLAL NEHRU STADIUM DELHI - 110 003. 2. THE INCOME TAX OFFCER WARD 5(2)(1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU - 560 095. …RESPONDENTS (BY SRI Y.V.RAVIRAJ AND SRI M.DILIP, ADVOCATES) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ASSESSMENT ORDER PASSED UNDER SECTION 147 R.W.S. 144 R.W.S. 144B OF THE ACT DTD. 29.03.2023 BEARING DIN NO. ITBA/AST/S/147/2022-23/1051562962(1) ISSUED BY THE R1 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-A1; QUASHING THE COMPUTATION SHEET DTD 29.03.2023 BEARING DIN AND DOCUMENT NO. ITBA/AST/S/183/2022- 23/1051563114(1) ISSUED BY THE R1 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-A2; QUASHING THE DEMAND NOTICE DTD 29.03.2023 ISSUED UNDER SECTION 156 OF THE ACT BEARING DIN AND NOTICE NO.ITBA/AST/S/156/2022-23/1051563072(1) BY THE R1 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-A3; QUASHING THE NOTICE UNDER SECTION 148A(B) OF THE ACT DTD 15.03.2022 BEARING DIN NO.ITBA/AST/F/148A(SCN)/2021- 22/1040768617(1) BY THE R2 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-B1; QUASHING THE ORDER PASSED UNDER SECTION 148A(D) OF THE ACT DTD 31.03.2022 BEARING DIN NO.ITBA/AST/F/148A/2021-22/1042200203(1) BY THE R2 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-B2; QUASHING THE NOTICE U/S 148 OF THE ACT DT.31.03.2022 BEARING DIN NO.ITBA/AST/S/148_1/2021-22/1042353176(1) BY THE R2 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-B3. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39452 WP No. 9132 of 2023 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/AST/S/156/2022- 23/1051563072(1) dated 29.03.2023, ITBA/AST/F/148A(SCN)/2021-22/1040768617(1) dated 15.03.2022, ITBA/AST/S/148_1/2021-22/1042353176(1) dated 31.03.2022, computation sheet No.ITBA/AST/S/183/2022-23/1051563114(1) dated 29.03.2023 and order Nos.ITBA/AST/S/147/2022- 23/1051562962(1) dated 29.03.2023 and ITBA/AST/F/148A/2021-22/1042200203(1) dated 31.03.2022 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Annamalai S., 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 - 4 - HC-KAR NC: 2025:KHC:39452 WP No. 9132 of 2023 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/S/156/2022-23/1051563072(1) dated 29.03.2023, ITBA/AST/F/148A(SCN)/2021- 22/1040768617(1) dated 15.03.2022, ITBA/AST/S/148_1/2021-22/1042353176(1) dated 31.03.2022, computation sheet No.ITBA/AST/S/183/2022-23/1051563114(1) dated 29.03.2023 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. - 5 - HC-KAR NC: 2025:KHC:39452 WP No. 9132 of 2023 (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.: 334 CT:SS