- 1 - HC-KAR NC: 2025:KHC:36530 WP No. 24312 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. 24312 OF 2023 (T-IT) BETWEEN: CENTRAL TAX AND CUSTOMS STAFF CREDIT COOPERATIVE SOCIETY LIMITED A COOPERATIVE SOCIETY REGISTERED UNDER KARNATAKA CO-OPERATIVE SOCIETIES ACT, 1959 REPRESENTED HEREIN BY ITS SECRETARY SHRI BHASKARA A.L. HAVING ITS REGISTERED OFFICE AT CR BUILDING ANNEXE II, D BLOCK BASEMENT, QUEENS ROAD BANGALORE - 560 001. …PETITIONER (BY SRI. SANDEEP HUILGOL, ADVOCATE) AND: 1. THE ASSESSMENT UNIT/VERIFICATION UNIT/TECHNICAL UNIT/REVIEW UNIT INCOME TAX DEPARTMENT, 2ND FLOOR, JAWAHARLAL NEHRU STADIUM, NEW DELHI – 110003. 2. INCOME TAX OFFICER WARD 1(2) (1), BANGALORE, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BANGALORE – 560095. 3. PRINCIPAL COMMISSIONER OF INCOME TAX, Digitally signed by NAGAVENI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:36530 WP No. 24312 of 2023 BANGALORE -1 BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BANGALORE – 560095. …RESPONDENTS (BY SRI. Y.V.RAVI RAJ AND SRI M.DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLE 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO QUASH THE IMPUGNED ASSESSMENT ORDER DTD 17.03.2023 BEARING DIN NO.ITBA/AST/S/147/2022-23/1050870293(1) PASSED BY R1 U/S 147 R.WS.144 AND 144B OF THE INCOME TAX ACT, 1961 ANNEXURE-A1 AND ETC. 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 is before this Court seeking the following prayers: “i) Quashing the impugned assessment order dated 17.03.2023 bearing DIN No. ITBA/AST/S/147/2022- 23/1050870293(1) passed by Respondent No. 1 under Section 147 r.w.s. 144 and 144B of the Income-tax Act, 1961 (Annexure 'A-1'); (ii) Quashing the impugned computation sheet dated 17.03.2023 bearing DIN No. ITBA/AST/S/185/2022- - 3 - HC-KAR NC: 2025:KHC:36530 WP No. 24312 of 2023 23/1050870302(1) issued by Respondent No. 1 (Annexure 'A-2'); (iii) Quashing the impugned Notice of demand dated 17.03.2023 bearing DIN No. ITBA/AST/S/156/2022- 23/1050870304(1) issued by Respondent No. 1, under the Section 156 of the Income-tax Act, 1961 (Annexure 'A-3'); (iv) Quashing the impugned order dated 29.03.2022 bearing DIN and Notice No. ITBA/AST/F/148A/2021- 22/1041961972(1) passed by the 2nd Respondent under Section 148A(d) of the Income-tax Act, 1961 (Annexure 'E-1'); (v) Quashing the impugned notice dated 29.03.2022 bearing DIN and Notice No.ITBA/AST/S/148_1/2021- 22/1042002151(1) issued by the 2nd Respondent under Section 148 of the Income-tax Act, 1961 (Annexure 'E- 2'); and (vi) Pass such order that this Hon'ble Court, may seem fit, in the facts and circumstances of the case, and in the interest of justice and equity.” 2. Heard Sri Sandeep Huilgol, learned counsel for the petitioner, Sri.Y.V.Ravi Raj and Sri.M.Dilip, learned counsels for the respondents. 3. The grounds projected in the subject petition in support of the prayers 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 - HC-KAR NC: 2025:KHC:36530 WP No. 24312 of 2023 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 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 - 5 - HC-KAR NC: 2025:KHC:36530 WP No. 24312 of 2023 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 357