- 1 - HC-KAR NC: 2025:KHC:37634 WP No. 23541 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 23541 OF 2024 (T-IT) BETWEEN: J B KEMPANNA SETTY CHARITIES REPRESENTED BY ITS TREASURER SRI. KEMPANNA CHETTY SON OF LATE SRI. ARASAPPA SETTY AGED ABOUT 69 YEARS, NO. 73, OTC ROAD NAGARTHAPET MAIN ROAD, BENGALURU - 560 002, PAN: AAATJ8591R …PETITIONER (BY SRI. ANNAMALAI S, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD 3(1)(3), BANGALORE BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 2. THE PRINCIPAL COMMISSIONER OF INCOME-TAX, BENGALURU-3, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095 …RESPONDENTS BY SRI. M. THIRUMALESH, ADVOCATE A/W SRI. GANESH GHALE, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37634 WP No. 23541 of 2024 THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE DTD. 07.02.2024 ISSUED UNDER SECTION 148A(b) OF THE ACT BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2023-24/1060608447(1) ISSUED BY THE R-1 FOR THE ASSESSMENT YEAR 2020-21 HEREIN MARKED AS ANNX-A1 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 is before this Court seeking the following prayer: "i) Issue a writ of Certiorari or direction in the nature of a writ or certiorari quashing the notice dated 07.02.2024 issued under section 148A(b) of the Act bearing DIN & Notice No.ITBA/AST/F/148(SCN)/2023-24/1060608447(1) issued by the Respondent No.1 for the assessment year 2020-21 herein marked as Anenxure-A1. ii) Issue a writ of Certiorari or direction in the nature of a writ or certiorari quashing the order passed under Section 148A(d) of the ct dated 26/03/2024 bearing DIN & Notice No.ITBA/AST/F/148A/2023-24/106335190(1) issued by the Respondent No.1 for the assessment year 2020-21 herein Marked as Annexure-A2. iii) Issue a writ of Certiorari or direction in the nature of a writ or certiorari quashing the notice dated 26/03/2024 issued under section 148 of the Act bearing DIN & Notice No.ITBA/AST/S/148- - 3 - HC-KAR NC: 2025:KHC:37634 WP No. 23541 of 2024 1/2023-24/1063351446(1) issued by the Respondent No.1 for the assessment year 2020-21 herein marked as Annexure-A3. iv) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri M. Thirumalesh, learned counsel along with Sri Ganesh Bhale, 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 show cause notices issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All - 4 - HC-KAR NC: 2025:KHC:37634 WP No. 23541 of 2024 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 BSV List No.: 1 Sl No.: 0 CT: BHK