- 1 - HC-KAR NC: 2025:KHC:34893 WP No. 16033 of 2024 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. 16033 OF 2024 (T-IT) BETWEEN: 1. DR. SUSHMA TEJWANI DAUGHTER OF SRI SOMANDAS BHURAMAL GOLANI AGED ABOUT 51 YEARS 1201, J BLOCK, MELROSE CONCORDE MANHATTAN, OPP. WIPRO GATE -16 ELECTRONIC CITY BANGALORE - 560 100. KARNATAKA. …PETITIONER (BY SRI. MADHUSUDHAN U A, ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME CIRCLE-4(1)(1),BENGALURU BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU -560 095. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX-2, BENGALURU BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU -560 095. …RESPONDENTS (BY SRI E I SANMATHI, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:34893 WP No. 16033 of 2024 QUASHING THE NOTICE ISSUED UNDER SECTION 148 OF THE INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2020-21 ISSUED ON 27.03.2024 BY THE RESPONDENT NO.1 BEARING DIN NO. ITBA/AST/S/148 1/2023-24/1063489612(1) HEREIN MARKED AS ANNEXURE-A AND QUASHING APPROVAL UNDER SECTION 151 OF THE ACT DATED 27.03.2024 OF THE ACT FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO.2 BEARING DIN AND NOTICE NO.ITBA/AST/S/118/2023- 24/1063488556(1). COPY OF THE APPROVAL UNDER SECTION 151 OF THE ACT DATED 27.03.2024 IS ENCLOSED AND MARKED AS ANNEXURE-B 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 - Assessee is before this Court seeking quashment of notice bearing No.ITBA/AST/S/148_1/2023- 24/1063489612(1) dated 27.03.2024 and approval No.ITBA/AST/S/118/2023-24/1063488556(1) dated 27.03.2024 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Madhusudhan U.A., learned counsel for the petitioner and Sri E.I.Sanmathi, learned counsel for the respondents. - 3 - HC-KAR NC: 2025:KHC:34893 WP No. 16033 of 2024 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 notice bearing No. ITBA/AST/S/148_1/2023-24/1063489612(1) dated 27.03.2024 and approval No.ITBA/AST/S/118/2023-24/1063488556(1) dated 27.03.2024 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. - 4 - HC-KAR NC: 2025:KHC:34893 WP No. 16033 of 2024 (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.: 377 CT.SM