- 1 - HC-KAR NC: 2025:KHC:37632 WP No. 19470 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 19470 OF 2024 (T-IT) BETWEEN: KARAN BAGARIA AGED ABOUT 40 YEARS SON OF LATE SRI. SUBHASH BAGARIA 11, KEMWELL HOUSE, TUMKUR ROAD YESHWANTHPUR S.O., BENGALURU - 560 022. …PETITIONER (BY SRI. MADHUSUDHAN U.A, ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3) CENTRAL REVENUE BUILDING QUEENS ROAD, BENGALURU - 560 001. 2. THE DIRECTOR GENERAL OF INCOME TAX (INVESTIGATION) CENTRAL REVENUE BUILDING QUEENS ROAD, BENGALURU - 560 001 …RESPONDENTS (BY SRI. Y.V. RAVI RAJ, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION F INDIA PRAYING TO A) QUASHING THE NOTICE DATED 31.03.2024 ISSUED UNDER SECTION 148A(B) OF THE INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2017-18 BY THE RESPONDENT NO.1 BEARING DIN NO. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37632 WP No. 19470 of 2024 ITBA/AST/F/148A(SCN)/2023-24/1063795285(1) HEREIN MARKED AS ANNEXURE - A1. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayer: "a) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 31.03.2024 Issued under section 148A(b) of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent No.1 bearing DIN No. ITBA/AST/F/148A(SCN)/202324/1063795285(1)here in marked as Annexure - A1. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 12.04.2024 issued under section 148A(b) of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent No.1 bearing DIN No. ITBA/AST/F/148A(SCN)/2024-25/1064074123(1) herein marked as Annexure- A2. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of order dated 25.04.2024 passed under 148A(d) of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent. No.1 bearing DIN & Notice No. ITBA/AST/F/148A/2024- 25/1064373107(1) passed by the Respondent No.1 herein marked as Annexure - АЗ. - 3 - HC-KAR NC: 2025:KHC:37632 WP No. 19470 of 2024 d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 25.04.2024 issued under section 148 of the Income Tax Act, 1961 for the Assessment Year 2017-18 by the Respondent No.1 bearing DIN & Order ITBA/AST/S/148_1/2024-25/1064373409(1) No. marked as Annexure - A4. e) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Sri Madhusudhan U.A., learned counsel for the petitioner, Sri Y.V.Raviraj 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: - 4 - HC-KAR NC: 2025:KHC:37632 WP No. 19470 of 2024 ORDER (i) The impugned show cause notices 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 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE BSV List No.: 1 Sl No.: 0 CT: BHK