- 1 - HC-KAR NC: 2025:KHC:37401 WP No. 31148 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 31148 OF 2024 (T-IT) BETWEEN: VAIDIC DHARMA SANSTHAN A REGISTERED PUBLIC CHARITABLE RELIGIOUS AND EDUCATIONAL TRUST HAVING ITS REGISTERED OFFICE AT: VVMP CAMPUS, 21ST K M KANAKAPURA ROAD, UDAYAPURA BENGALURU - 560 082 (PAN. AABTV0776H) UNDER REGISTERED INDIA TRUST DEED ACT 1882 REPRESENTED BY ITS TRUSTEE SHRI. ROHIT SIKKA AGED ABOUT 49 YEARS, OCCUPATION: TRUSTEE RESIDING AT ART OF LIVING INTERNATIONAL CENTRE, 21ST K M KANAKAPURA ROAD, UDAYAPURA, BENGALURU - 560 082 …PETITIONER (BY SRI. K.R. VASUDEVAN, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37401 WP No. 31148 of 2024 AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX EXEMPTIONS, CIRCLE-1 UNITY BUILDING ANNEXE, MISSION ROAD BENGALURU - 560 027. 2. THE ASSESSMENT UNIT/ INCOME TAX OFFICER INCOME TAX DEPARTMENT, 2ND FLOOR, JAWAHARLAL NEHRU STADIUM NEW DELHI - 110 003. 3. THE COMMISSIONER OF INCOME TAX EXEMPTIONS, UNITY BUILDING ANNEXE MISSION ROAD, BENGALURU - 560 027. …RESPONDENTS (BY SRI. ARAVIND V CHAVAN, ADVOCATE FOR R1 TO R2) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF PRAYING TO IMPUNGED NOTICE DATED 22.01.2024 ISSUED BY THE RESPONDENT NO.1 UNDER SECTION 148A(b) OF THE IT ACT FOR THE AY 2017-18 IN DIN & : ITBA/ASTF/F/148A(SCN)/2023-24/1059975053(1) (ANNEXURE-F) AND ETC., THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:37401 WP No. 31148 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “i. issue a writ of certiorari or any other writ as the Hon'ble High Court may deem fit and quash the following: ANNEXURE 'F' Impugned notice dated 22.01.2024 issued by the Respondent No.1 under Section 148A(b) of the IT Act for the AY 2017-18 in DIN & Notice No.: ITBA/AST/F/148A(SCN)/2023- 24/1059975053(1) ANNEXURE 'H' Impugned order dated 18.03.2024 passed by the Respondent No.1 under Section 148A(d) of the IT Act for the AY 2017-18 in DIN & Notice No.: ITBA/AST/F/148A/2023- 24/1062868756(1) ANNEXURE 'H1' Impugned notice dated 18.03.2024 Issued by the Respondent No.1 under Section 148 of the IT Act for the AY 2017-18 in DIN & Notice No.: ITBA/AST/S/148_1/2023- 24/1062870790(1) ANNEXURE 'J' Impugned notice dated 08.07.2024 issued by the Respondent No.2 under section 142(1) of the IT Act for the AY 2017-18 in DIN: ITBA/AST/F/142(1)/2024- 25/1066491549(1) ANNEXURE 'L' Impugned notice dated 04.10.2024 issued by the Respondent No.2 under section 142(1) of the IT Act for the AY 2017-18 in DIN: - 4 - HC-KAR NC: 2025:KHC:37401 WP No. 31148 of 2024 ITBA/AST/F/142(1)/2024- 25/1069378157(1) ii. issue any other writ, order or direction to which the Petitioner is found entitled to in the present facts and circumstances and in the interests of justice and equity." 2. Heard Shri K.R. Vasudevan., learned counsel appearing for the petitioner and Shri Aravind V. Chavan, learned counsel appearing for respondents No.1 to 3. 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 show cause notice 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 this petition would stand quashed. - 5 - HC-KAR NC: 2025:KHC:37401 WP No. 31148 of 2024 (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 JY List No.: 1 Sl No.: 175 CT: BHK