- 1 - HC-KAR NC: 2025:KHC:35672 WP No. 22276 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. 22276 OF 2024 (T-IT) BETWEEN: BYRANAYAKANAHALLY CHANNABASAPPA PRABHUSWAMY, SON OF LATE SRI. CHANBASAPPA, AGED 65 YEARS, # 246, SOWMYASHREE NILAYA, 3RD CROSS, VINAYAKA NAGAR, TIPTUR, TUMKUR-572 201. …PETITIONER (BY SRI.SHREEHARI, ADVOCATE) AND: 1. THE INCOME TAX OFFICER, WARD 1, TIPTUR, THE ASSESSING OFFICER UNDER THE INCOME TAX ACT, 1961, JAYADEVA COMPLEX, TIPTUR, TUMKUR DISTRICT-572 201. 2. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA AND GOA, THE SPECIFIED AUTHORITY UNDER THE SECTION 151 OF THE INCOME TAX ACT, 1961, CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU-560 001. 3. NATIONAL FACELESS ASSESSMENT CENTRE NOW KNOWN AS NATIONAL E-ASSESSMENT CENTRE, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:35672 WP No. 22276 of 2024 REP. BY PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX (NEAC), ROOM NO. 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110 003. …RESPONDENTS (BY SRI.M.THIRUMALESH, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE UNDER CLAUSE (b) OF SECTION 148A OF THE INCOME TAX ACT 1961 DTD. 15.02.2024 FOR THE A.Y. 2017-18 ISSUED BY THE RESPONDENT NO. 1 BEARING DIN VIZ. ITBA/AST/F/148A(SCN)/2023-24/1060976923(1) WHICH IS ENCLOSED AS ANNEXURE-A; INVOKING THE EXTRA- ORDINARY JURISDICTION OF THIS HON'BLE COURT SEEKING QUASHING OF THE NOTICE UNDER CLAUSE (d) OF SECTION 148A OF THE INCOME TAX ACT 1961 DATED 27/03/2024 FOR THE A.Y. 2017-18 ISSUED BY THE RESPONDENT NO. 1 BEARING DIN VIZ., ITBA/AST/F/148A/2023-24/1063466836(1) WHICH IS ENCLOSED AS ANNEXURE C AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN 'B' GROUP THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:35672 WP No. 22276 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “a. Issue a Writ of Certiorari or direction in the nature of writ of certiorari quashing the notice under clause (b) of section 148A of the Income Tax Act 1961 dated 15/02/2024 for the A.Y. 2017-18 issued by the Respondent No.1 bearing DIN viz., ITBA/AST/F/148A(SCN)/2023-24/1060976923(1) which is enclosed as Annexure A. b. Invoking the extra-ordinary jurisdiction of this Hon'ble Court seeking quashing of the notice under clause (d) of section 148A of the Income Tax Act 1961 dated 27/03/2024 for the A.Y. 2017-18 issued by the Respondent No.1 bearing DIN viz., ITBA/AST/F/148A/2023-24/1063466836(1) which is enclosed as Annexure C. c. Invoking the extra-ordinary jurisdiction of this Hon'ble Court seeking quashing of the notice under section 148 of the Income Tax Act 1961 dated 27/03/2024 for the A.Y. 2017-18 issued by the Respondent No.1 bearing DIN viz., ITBA/AST/S/148_1/2023-24/1063467997(1) which is enclosed as Annexure D. d. And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” - 4 - HC-KAR NC: 2025:KHC:35672 WP No. 22276 of 2024 2. Heard Sri.Shreehari, learned counsel for the petitioner, Sri.M.Thirumalesh, learned counsel 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. 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 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in this petition would stand quashed. - 5 - HC-KAR NC: 2025:KHC:35672 WP No. 22276 of 2024 (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 CBC List No.: 1 Sl No.: 392 CT.SM