- 1 - HC-KAR NC: 2025:KHC:39266 WP No. 12857 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 12857 OF 2025 (T-IT) BETWEEN: NAGARAJA GOWDA AGED ABOUT 62 YEARS NO.01, HOSPETE HOKKALY, HALESORAB, SORAB, SHIMOGA - 577 429 …PETITIONER (BY SRI. ANIRUDHA R. NAYAK, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD-1 AND TPS, NO.75, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39266 WP No. 12857 of 2025 100 FT. ROAD, GOPAL GOWDA EXTENSION, SHIVAMOGA - 577 201 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX, C R BUILDINGS, QUEENS ROAD, BENGALURU - 560 001 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO (A) QUASH THE ORDER DATED 10.03.2023 BEARING NO.ITBA/AST/F/148A/2022- 23/1050594569(1)(ANNEXURE-B) PASSED BY THE 1ST RESPONDENT UNDER SECTION 148A(d) OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39266 WP No. 12857 of 2025 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court, seeking the following prayer: "(a) Quashing the order dated 10.03.2023 bearing No. ITBA/AST/F/148A/2022-23/1050594569 (1) (Annexure B) passed by the 1st Respondent under Section 148A(d) of the Act for the assessment year 2019-20; (b) Quashing the order dated 13.03.2024 bearing No. ITBA/AST/F/148A/2023-24/1062547797 (1) (Annexure J) passed by the 1st Respondent under Section 148A(d) of the Act for the assessment year 2020-21; (c) Quashing the order dated 30.01.2024 bearing No. ITBA/AST/S/147/2023-24/1060258096 (1) (Annexure G) passed by the 1st Respondent under Section 147 of the Act for the assessment year 2019-20; (d) Quashing the order dated 04.03.2025 bearing No. ITBA/AST/S/147/2024-25/1074011734 (1) (Annexure N) passed by the 1st Respondent under Section 147 of the Act for the assessment year 2020-21; (e) Quashing the demand notice dated 30.01.2024 ITBA/AST/S/156/2023-24/10602 bearing No. 58342 (1) issued by the 1st Respondent (Annexure H) to the Petitioner under Section 156 of the Act for the assessment year 2019-20; (f) Quashing the Demand notice bearing ITBA/AST/S /156/2024-25/1074011874 (1) dated 04.03.2025 u/s 156 in Annexure P; - 4 - HC-KAR NC: 2025:KHC:39266 WP No. 12857 of 2025 (g) pass such other or further orders as this Hon'ble Court may deem fit in the facts and circumstances of the case, in the interests of justice and equity.” 2. Heard Sri Anirudha R. Nayak, learned counsel for the petitioner 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 show cause notice issued by the jurisdictional Assessing Officer outside the scope of Section 151-A of the Act stand obliterated. - 5 - HC-KAR NC: 2025:KHC:39266 WP No. 12857 of 2025 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 SJK CT:SG List No.: 2 Sl No.: 88