- 1 - HC-KAR NC: 2025:KHC:39448 WP No. 8955 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. 8955 OF 2023 (T-IT) BETWEEN: SRI RAMAIAH SHAMANNA SON OF SRI RAMAIAH AGED ABOUT 77 YEARS NO.21/1, SERPENTINE ROAD KUMARA PARK WEST BENGALURU – 560 020. …PETITIONER (BY SRI ANNAMALAI S., ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - 2(2)(1), BENGALURU BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU – 560 095. 2. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KARNATAKA AND GOA REGION BMTC BUILDING, 80 FEET ROAD Digitally signed by NAGAVENI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:39448 WP No. 8955 of 2023 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU – 560 095. …RESPONDENTS (BY SRI E.I.SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE NOTICE ISSUED UNDER SECTION 148A(B) OF THE ACT DTD 30.03.2023 OF THE ACT FOR THE ASSESSMENT YEAR 2016-17 BY THE R-1 BEARING NO. DIN AND LETTER NO. ITBA/AST/F/148A(SCN)/2022-23/1051673903(1) HEREIN MARKED AS ANNX-A1; QUASHING THE ORDER DTD 13.04.2023 ISSUED UNDER SECTION 148A(D) OF THE ACT FOR THE ASSESSMENT YEAR 2016-17 BY THE R-1 BEARING NO. DIN AND ORDER NO. ITBA/AST/F/148A/2023- 24/1052077097(1) HEREIN MARKED AS ANNX-A2; QUASHING THE NOTICE DTD 13.04.2023 ISSUED UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2016-17 BY THE R-1 BEARING DIN AND DOCUMENT NO. ITBA/AST/S/148_1/2023- 24/1052077496(1) HEREIN MARKED AS ANNX-A3. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39448 WP No. 8955 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/F/148A(SCN)/2022-23/1051673903(1) dated 30.03.2023, ITBA/AST/S/148_1/2023-24/1052077496(1) dated 13.04.2023 and order No.ITBA/AST/F/148A/2023- 24/1052077097(1) dated 13.04.2023 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 E.I.Sanmathi, 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 - 4 - HC-KAR NC: 2025:KHC:39448 WP No. 8955 of 2023 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned notices bearing No. ITBA/AST/F/148A(SCN)/2022-23/1051673903(1) dated 30.03.2023, ITBA/AST/S/148_1/2023- 24/1052077496(1) dated 13.04.2023 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. (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:39448 WP No. 8955 of 2023 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 330 CT:SS