- 1 - HC-KAR NC: 2025:KHC:49714 WP No. 35662 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 35662 OF 2025 (T-IT) BETWEEN: 1. SRI. MANJUNATH RAMA REDDY SON OF S K RAMA REDDY AGED ABOUT 60 YEARS NO.704, BEHIND SVP COLLEGE, SARJAPURA, BANGALORE - 562 125 …PETITIONER (BY SRI. JOSEPH VARGHESE, ADVOCATE) AND: 1. ASSESSMENT UNIT INCOME TAX DEPARTMENT, REP. BY ADDL/JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/ INCOME TAX OFFICER, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO 401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI - 110 003 2. THE INCOME TAX OFFICER, WARD-4(2)(1), BMTC BUILDING, KORMANGALA, BANGALORE - 560 095 3. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA AND GOA, CENTRAL REVENUE BUILDING, Digitally signed by SHARADAVANI B Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:49714 WP No. 35662 of 2025 NO. 1, QUEEN'S ROAD, BENGALURU - 560 001. …RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE ISSUED UNDER SECTION 148A(B) OF THE ACT DATED 23.03.2022 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2021-22/1041321951(1) HEREIN MARKED AS ANNEXURE - A1 AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER Petitioner in this petition, seeks for the following reliefs: "Wherefore it is prayed that this Hon'ble Court be pleased to: i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 148A(b) of the Act dated 23.03.2022 bearing DIN & Notice No. ITBA/AST/F/148A(SCN)/2021-22/1041321951(1) marked as Annexure - A1. herein ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed under section 148A(d) of the Act dated 31.03.2022 bearing DIN No. ITBA/AST/F/148A/2021- 22/1042288751(1) herein marked as Annexure - A2. 6) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice - 3 - HC-KAR NC: 2025:KHC:49714 WP No. 35662 of 2025 issued under section 148 of the Act dated 31.03.2022 bearing DIN No. ITBA/AST/S/148_1/2021-22/1042358264 (1) herein marked as Annexure - A3. iv) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitioner invited my attention to the order of a Co- ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order. - 4 - HC-KAR NC: 2025:KHC:49714 WP No. 35662 of 2025 4. Per contra, learned counsel for the respondents submits that there is no merit in the petition and that the same is liable to be dismissed. 5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under: "13. I, therefore, pass the following: O R D E R (i) The impugned show cause notices issued by the jurisdictional Assessing Officer outside the scope of Section 151-A of the Act stand obliterated. All further proceedings initiated thereto, challenged in these cases would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. - 5 - HC-KAR NC: 2025:KHC:49714 WP No. 35662 of 2025 (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of these petitions would become necessary." 6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of co-ordinate Bench of this Court in Ramachandra Reddy's case (supra). 7. In the result, I pass the following: ORDER (i) The petition is allowed and disposed of in terms of the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025. (ii)The impugned show cause notices and consequential orders, notices etc., at Annexures- A1, A2 and A3, dated 23.03.2022, 31.03.2022 and 31.03.2022 respectively are hereby quashed. (iii) Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, - 6 - HC-KAR NC: 2025:KHC:49714 WP No. 35662 of 2025 subsequent to disposal of the matters pending before the Apex Court and all rival contentions between the parties in this regard are kept open and no opinion is expressed on the same. Sd/- (S.R.KRISHNA KUMAR) JUDGE BSV List No.: 2 Sl No.: 19