- 1 - HC-KAR NC: 2025:KHC:35238 WP No. 19590 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. 19590 OF 2024 (T-IT) BETWEEN: 1. BANGALORE GORAKSHAN SHALA A SOCIETY REGISTERED UNDER THE MYSORE SOCIETIES ACT, 1961 REPRSENTED BY ITS SECRETARY SON OF SRI. C. KISHANLAL AGED ABOUT 77 YEARS NEAR OUTER RING ROAD MAHADEVAPURA POST DODDANIKKUNDI BANGALORE - 560 048. …PETITIONER (BY SRI. MADHUSUDHAN U A, ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX EXEMPTIONS, CIRCLE-1 UNITY BUILDING ANNEXE, MISSION ROAD BANGALORE - 560 027. 2. THE COMMISSIONER OF INCOME TAX (EXEMPTIONS) CENTRAL REVENUE BUILDING QUEENS ROAD BANGALORE -560 001. …RESPONDENTS (BY SRI ARAVIND V CHAVAN, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:35238 WP No. 19590 of 2024 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 DATED 24.01.2024 OF THE ACT FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO.1 BEARING DIN AND LETTER NO. ITBA/AST/F/148A(SCN)/2023- 24/1060093973(1). HEREIN MARKED AS ANNEXURE - A1 AND QUASHING THE ORDER DATED 08.02.2024 PASSED UNDER SECTION 148A(B) OF THE ACT FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO.1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2023-24/1060638719(1) HEREIN MARKED AS ANNEXURE - A 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)/2023-24/1060093973(1) dated 24.01.2024, ITBA/AST/F/148A/2023-24/1063698071(1) dated 30.03.2024, ITBA/AST/S/148_1/2023-24/1063698746(1) dated 30.03.2024, approval No.ITBA/AST/S/118/2023- 24/1063687021(1) dated 30.03.2024 and order Nos.ITBA/AST/F/148A(SCN)/2023-24/1060638719(1) dated 08.02.2024, ITBA/AST/F/148A(SCN)/2023-24/1062868103(1) dated 18.03.2024 passed by the respondents – Revenue under - 3 - HC-KAR NC: 2025:KHC:35238 WP No. 19590 of 2024 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 Aravind V. Chavan, 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)/2023-24/1060093973(1) dated 24.01.2024, ITBA/AST/F/148A/2023- 24/1063698071(1) dated 30.03.2024, ITBA/AST/S/148_1/2023-24/1063698746(1) dated 30.03.2024, approval No.ITBA/AST/S/118/2023- - 4 - HC-KAR NC: 2025:KHC:35238 WP No. 19590 of 2024 24/1063687021(1) dated 30.03.2024 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 NVJ List No.: 1 Sl No.: 388 CT.SM