- 1 - HC-KAR NC: 2025:KHC:34282 WP No. 16683 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. 16683 OF 2023 (T-IT) BETWEEN: 1. SRI. CHINNASWAMY SUNDER RAJU LEGAL HEIR OF LATE SRI AKKALARAJU SOLARAJU CHINNASWAMY RAJU AGED ABOUT 66 YEARS RESIDING AT NO.294, 16TH CROSS UPPER PALACE ORCHARDS SADASHIVANAGAR BANGALORE - 560 080. …PETITIONER (BY SRI. ANNAMALAI S, ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4) CENTRAL REVENUE BUILDINGS NO.1, QUEENS ROAD BANGALORE - 560 001. 2. THE DIRECTOR GENERAL OF INCOME TAX (INVESTIGATION) CENTRAL REVENUE BUILDING NO.1, QUEENS ROAD BANGALORE - 560 001. …RESPONDENTS (BY SRI Y V RAVI RAJ AND SRI M DILIP, ADVOCATES) Digitally signed by NAGAVENI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:34282 WP No. 16683 of 2023 THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE ISSUED U/S 148A(B) OF THE ACT DT. 31.01.2023 BEARING DIN AND LETTER NO. ITBA/AST/F/148A(SCN)/2022-23/1049289205(1) ISSUED BY THE R1 FOR THE AY. 2018-19 HEREIN MARKED AS ANNX-A1 AND QUASH THE ORDER DT. 20.03.2023 PASSED U/S 148A(D) OF THE ACT BEARING DIN AND ORDER NO. ITBA/COM/M/17/2022-23/1051016792(1) ISSUED BY THE R1 FOR THE AY 2018-19 HEREIN MARKED AS ANNX-A2 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 notices bearing No.ITBA/AST/F/148A(SCN)/2022-23/1049289205(1) dated 31.01.2023, ITBA/COM/M/17/2022-23/1051063545(1) dated 21.03.2023 and order Nos.ITBA/COM/M/17/2022- 23/1051016792(1) dated 20.03.2023, ITBA/AST/S/147/2024- 25/1073176105(1) dated 07.02.2025 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. - 3 - HC-KAR NC: 2025:KHC:34282 WP No. 16683 of 2023 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri Y.V.Ravi Raj 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 notices bearing No. ITBA/AST/F/148A(SCN)/2022-23/1049289205(1) dated 31.01.2023, ITBA/COM/M/17/2022- 23/1051063545(1) dated 21.03.2023 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. - 4 - HC-KAR NC: 2025:KHC:34282 WP No. 16683 of 2023 (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 NVJ List No.: 1 Sl No.: 349 CT.sm