- 1 - HC-KAR NC: 2025:KHC:37890 WP No. 35312 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.35312 OF 2024 (T-IT) BETWEEN: SRI. S. S. NAGESHA SON OF LATE SUBRAMANYA S.N. AGED ABOUT 50 YEARS AMBIKA NAGARA, 2ND CROSS, MAKAN GURUMARANAHALLI, B.M ROAD, CHANNARAYAPATTANA, HASSAN – 573 116 …PETITIONER (BY SRI. SANDEEP HUILGOL., ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD 1 AND TPS, HASSAN AAYAKAR BHAVAN, 2ND STAGE, BELUR ROAD, HASSAN – 573 201 2. THE ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE INCOME TAX DEPARTMENT, 2ND FLOOR, JAWAHARLAL NEHRU STADIUM, NEW DELHI – 110 003 3. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, KARNATAKA & GOA GROUND FLOOR, CR BUILDING, NO.1 QUEENS ROAD, BENGALURU - 560 001 Digitally signed by NAGAVENI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:37890 WP No. 35312 of 2024 4. IDBI BANK LIMITED HASSAN BRANCH, KENCHAMBA ARCADE, SAMPIGE ROAD, HASSAN – 573 201. REPRESENTED HEREIN BY ITS BRANCH MANAGER 5. FEDERAL BANK, CHANNARAYAPATTANA BRANCH, GROUND FLOOR, MADHU COMPLEX, MYSORE ROAD, CHANNARAYAPATTANA – 573 116 REPRESENTED HEREIN BY ITS BRANCH MANAGER …RESPONDENTS (BY SRI. M. THIRUMALESH, ADVOCATE FOR R1 TO R3; SRI. T. P. MUTHANNA, ADVOCATE FOR R4; R-5 IS SERVED) THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE IMPUGNED BANK ATTACHMENT NOTICE DATED 08.11.2024 BEARING DIN AND NOTICE NO.ITBA/COM/F/17/2024- 25/1070209375(1) ISSUED BY RESPONDENT NO.1 UNDER SECTION 226 (3) OF THE INCOME-TAX ACT 1961 FOR ASSESSMENT YEARS 2015-16 AND 2016-17 IN RESPECT OF THE ACCOUNT MAINTAINED BY THE PETITIONER WITH THE 4TH RESPONDENT BANK (ANNEXURE-A) AND ETC THIS PETITION COMING ON FOR ORDERS THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:37890 WP No. 35312 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/COM/F/17/2024- 25/1070209375(1) dated 08.11.2024, ITBA/COM/F/17/2024- 25/1070209187(1) dated 08.11.2024, ITBA/AST/S/156/2022- 23/1049701065(1) dated 13.02.2023, ITBA/AST/S/156/2023- 24/1058167726(1) dated 23.11.2023, ITBA/PNL/S/272A(1)(d)_FL/2022-23/1049585094(1) dated 09.02.2023, ITBA/PNL/S/271AAC(1)/2022-23/1049701151(1) dated 13.02.2023, ITBA/PNL/S/156/2024-25/1064915272(1) dated 16.05.2024, ITBA/PNL/S/156/2024-25/1064943319(1) dated 16.05.2024, computation sheet Nos.ITBA/AST/S/114/2022-23/1049701058(1) dated 13.02.2023, ITBA/AST/S/114/2023-24/1058167722(1) dated 23.11.2023, computation sheet DIN Nos.2024201640416134111T dated 16.05.2024, 2024201640416134074T dated 16.05.2024, 2024201640416134096T dated 16.05.2024, letter No.ITBA/COM/F/17/2024-25/1064780846(1) dated 10.05.2024 - 4 - HC-KAR NC: 2025:KHC:37890 WP No. 35312 of 2024 and order No.ITBA/AST/S/147/2022-23/1049700968(1) dated 13.02.2023, ITBA/AST/S/147/2023-24/1058167641(1) dated 23.11.2023, ITBA/PNL/F/271F/2024-25/1064919101(1) dated 16.05.2024, DIN No.ITBA/PNL/F/271(1)(b)/2024- 25/1064943726(1) dated 16.05.2024, ITBA/PNL/F/271(1)(c)/2024-25/1064943756(1) dated 16.05.2024 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Sandeep Huilgol, learned counsel for the petitioner, Sri M. Thirumalesh, learned counsel for respondent No.1 and Sri T.P.Muthanna, learned counsel for respondent No.4. 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 - 5 - HC-KAR NC: 2025:KHC:37890 WP No. 35312 of 2024 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned notices bearing No. ITBA/COM/F/17/2024-25/1070209375(1) dated 08.11.2024, ITBA/COM/F/17/2024- 25/1070209187(1) dated 08.11.2024, ITBA/AST/S/156/2022-23/1049701065(1) dated 13.02.2023, ITBA/AST/S/156/2023- 24/1058167726(1) dated 23.11.2023, ITBA/PNL/S/272A(1)(d)_FL/2022-23/ 1049585094 (1) dated 09.02.2023, ITBA/PNL/S/271AAC(1)/2022-23/1049701151(1) dated 13.02.2023, ITBA/PNL/S/156/2024- 25/1064915272(1) dated 16.05.2024, ITBA/PNL/S/156/2024-25/1064943319(1) dated 16.05.2024, computation sheet Nos.ITBA/AST/S/114/2022-23/1049701058(1) dated 13.02.2023, ITBA/AST/S/114/2023- 24/1058167722(1) dated 23.11.2023, 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. (ii) Liberty is reserved to the respondents - revenue to revive the petition in the event, the Apex Court - 6 - HC-KAR NC: 2025:KHC:37890 WP No. 35312 of 2024 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 and I.A.No.1/2024 would be considered, in the event revival of this petition becomes necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 411