- 1 - HC-KAR NC: 2025:KHC:39440 WP No. 5472 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. 5472 OF 2023 (T-IT) BETWEEN: LEELAVATHI PADMANABHA MAHALE W/O SRI PADMANABHA MAHALE AGED ABOUT 73 YEARS NO.209/1, 4TH FLOOR PALACE CORNER APARTMENTS SADASHIVANAGAR BENGALURU – 560 080. …PETITIONER (BY SRI MADHUSUDHAN U. A., ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD-2(2)(3), 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 BMTC BUILDING, 80 FEET ROAD Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39440 WP No. 5472 of 2023 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU – 560 095. 3. ASSESSMENT UNIT/INCOME TAX OFFICER NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT MINISTRY OF FINANCE ROOM NO.401, 2ND FLOOR E-RAMP, JAWAHARLAL NEHRU STADIUM DELHI – 110 003. …RESPONDENTS (BY SRI E.I.SANMATHI, ADVOCATE) THIS WRIT PETITION 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 19.03.2022 OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R-1 BEARING DIN AND NOTICE NO.ITBA/AST/F/148A(SCN)/2021-22/1041064495(1) HEREIN MARKED AS ANNX-A1; QUASHING THE ORDER DTD 30.03.2022 PASSED UNDER SECTION 148A(D) OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R-1 BEARING DIN AND NOTICE NO.ITBA/AST/F/148A/2021- 22/1042096811(1) HEREIN MARKED AS ANNX-A2; QUASHING THE NOTICE DTD 30.03.2022 ISSUED UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R-1 BEARING DIN AND NOTICE NO.ITBA /AST/S/148_1/2021- 22/1042101867(1) HEREIN MARKED AS ANNX-A3. - 3 - HC-KAR NC: 2025:KHC:39440 WP No. 5472 of 2023 THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, 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)/2021-22/1041064495(1) dated 19.03.2022, ITBA/AST/S/148_1/2021-22/1042101867(1) dated 30.03.2022 and order No.ITBA/AST/F/148A/2021- 22/1042096811(1) dated 30.03.2022 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Madhusudhan U.A., 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 - HC-KAR NC: 2025:KHC:39440 WP No. 5472 of 2023 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)/2021-22/1041064495(1) dated 19.03.2022 and ITBA/AST/S/148_1/2021- 22/1042101867(1) dated 30.03.2022 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. - 5 - HC-KAR NC: 2025:KHC:39440 WP No. 5472 of 2023 (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.: 323 CT:SS