Karnataka High Court
Karnataka Co Operative Sheep And Goat vs Income Tax Officer on 27 October, 2025
Author: S.R.Krishna Kumar
Bench: S.R.Krishna Kumar
-1-
NC: 2025:KHC:42608
WP No. 32093 of 2025
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 27TH DAY OF OCTOBER, 2025
BEFORE
THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
WRIT PETITION NO. 32093 OF 2025 (T-IT)
BETWEEN:
KARNATAKA CO OPERATIVE SHEEP AND GOAT
REARERS SOCIETIES FEDERATION LIMITED
A SOCIETY FORMED AS ASSOCIATION OF PERSONS
HAVING ITS REGISTERED OFFICE AT
KURIBHAVANA VETERINARY COLLEGE CAMPUS,
HEBBAL, BENGALURU - 560 024
(PAN AADAK4279M)
REPRESENTED BY ITS CHIEF EXECUTIVE OFFICER,
DR UMESY YADAV M.,
AGED ABOUT 42 YEARS,
DESIGNATION CEO,
R/AT BB-72, KHB COLONY,
KAVALBIRASANDRA, BENGALURU-560032
REGISTERED UNDER THE
KARNATAKA CO-OPERATIVE SOCIETY ACT, 1959
...PETITIONER
Digitally signed (BY SRI. B.S. BALACHANDRAN, ADVOCATE)
by CHANDANA
BM AND:
Location: High
Court of 1. INCOME TAX OFFICER
Karnataka WARD 6(3) (1), BENGALURU,
BMTC BUILDING, 80 FEET ROAD,
6TH BLOCK, NEAR KHB GAMES VILLAGE,
KORAMANGALA, BENGALURU - 560 095
2. THE ASSESSMENT UNIT
INCOME TAX DEPARTMENT, 2ND FLOOR,
JAWAHARLAL NEHRU STADIUM,
NEW DELHI - 110 003
3. THE PRINCIPAL COMMISSIONER OF INCOME TAX
BENGALURU-6, BMTC BUILDING,
-2-
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80 FT ROAD, 6TH BLOCK,
NEAR KHB GAMES VILLAGE,
KORAMANGALA,
BENGALURU - 560 095
4. THE MANAGER
THE KARNATAKA STATE CO OPERATIVE
APEX BANK LIMITED,
NO.18/2, 5TH MAIN ROAD,
GANGENAHALLI LAYOUT,
BENGALURU - 560 032
...RESPONDENTS
(BY SRI. M. DILIP, ADVOCATE)
THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE
CONTITUTION OF INDIA PRAYING TO ANNEXURE - A - IMPUGNED
NOTICE DATED 25.01.2024 ISSUED BY RESPONDENT NO.1 UNDER
SECTION 148A(B) OF THE ACT FOR AY 2017-18 IN DIN AND NOTICE
ITBA/AST/F/148A(SCN)/2023-24/1060097059(1) AND ETC.,
THIS PETITION, COMING ON FOR FINAL HEARING, THIS DAY,
ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
ORAL ORDER
In this petition, petitioner seeks for the following reliefs:-
"i. Issue a writ of certiorari or any other writ as the
Hon'ble High Court may deem fit and quash the
following:
ANNEXURE 'A' Impugned notice dated 25.01.2024
issued by Respondent No.1 under
section 148A(b) of the Act for AY 2017-
18 in DIN & Notice No.
ITBA/AST/F/148A(SCN)/2023-
24/1060097059(1).
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ANNEXURE 'A1' Impugned notice dated 11.02.2024
issued by Respondent No.1 under
section 148A(b) of the Act for AY 2017-
18 in DIN & Notice No.
ITBA/AST/F/148A(SCN)/2023-
24/1060764733(1)
ANNEXURE 'A2' Impugned notice dated 12.03.2024
issued by Respondent No.1 under
section 148A(b) of the Act for AY 2017-
18 in DIN & Notice No.
ITBA/AST/F/148A(SCN)/2023-
24/1062423403(1)
ANNEXURE 'B' Impugned order dated 21.03.2024
issued by Respondent No.1 under
section 148A(d) of the Act for AY 2017-
18 in DIN & Order No.
ITBA/AST/F/148A/2023-
24/1063117566(1)
ANNEXURE 'C' Impugned notice dated 21.03.2024
issued by Respondent No.1 under
section 148 of the Act for AY 2017-18 in
DIN & Notice No.
ITBA/AST/S/148_1/2023-
24/1063118128(1)
ANNEXURE 'G' Impugned assessment order dated
28.02.2025 passed by Respondent No.2
under section 147 read with section 144
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read with section 144B of the Act for AY
2017-18 in DIN & Order No.
ITBA/AST/S/147/2024-
25/1073852877(1)
ANNEXURE 'G1' Impugned computation sheet dated
28.02.2025 issued by Respondent No.2
under section 147 read with section 144
of the Act for AY 2017-18 in DIN &
Document No. ITBA/AST/S/215/2024-
25/1073853116(1)
Annexure 'G2' Impugned demand notice dated
28.02.2025 issued by Respondent No.1
under section 156 of the Act for AY
2017-18 in DIN & Notice No.
ITBA/AST/S/156/2024-
25/1073852963(1)
ANNEXURE 'H' Impugned garnishee notice dated
07.10.2025 issued by Respondent No.1
under section 226(3) to Respondent
No.4 for attachment of Petitioner's bank
account in DIN & Notice No.
ITBA/RCV/S/226(3)_1/2025-
26/1081497074(1)
ii. Lift the bank attachment placed by Respondent No.1
on the following bank accounts of the Petitioner vide
the impugned garnishee notice dated 07.10.2025
issued under section 226(3) in DIN & Notice No.
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ITBA/RC/S/226(3)_1/2025-26/1081497074(1)
(ANNEXURE 'H');
Account
Bank Account Number
Type
The Karnataka 10251110200000251
State Co-
Saving
operative Apex
Bank Limited
The Karnataka 1025102040000041
State Co-
Saving
operative Apex
Bank Limited
iii. 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 learned counsel for the petitioner and learned
counsel for the respondents and perused the material on record.
3. In addition to reiterating the various contentions urged
in the memorandum of petition and referring to the material on
record, learned counsel for the petitioner invited my attention to the
order of a Co-ordinate Bench of this Court in the case of
Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of
Income-tax - W.P.No.17352/2022 and connected matters -
dated 28.08.2025, in order to contend that the present petition
deserves to be allowed and disposed of in terms of the said order.
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4. Per contra, learned counsel for the respondents
submits that there is no merit in the petition and that the same is
liable to be dismissed.
5. As rightly contended by the learned counsel for the
petitioner the present petition is directly and squarely covered by
the decision of a Co-ordinate Bench of this Court in the case of
Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of
Income-tax - W.P.No.17352/2022 and connected matters -
dated 28.08.2025, the operative portion of which reads as under:
"13. I, therefore, pass the following:
ORDER
(i) The impugned show cause notices 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 these
cases would stand quashed.
(ii) Liberty is reserved to the respondents - revenue to
revive all these petitions in the event the Apex Court
would hold in favour of the Revenue in the pending
before it.
(iii) With the aforesaid liberty and to the aforesaid extent,
the petitions are allowed.
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(iv) Contentions of both the parties except the one noted
hereinabove, shall remain open to be considered in
the event revival of these petitions would become
necessary."
6. The aforesaid order is applicable to the facts and
circumstances of the instant case and consequently, the present
petition also deserves to be disposed of in terms of the judgment of
co-ordinate Bench of this Court in Ramachandra Reddy's case
(supra).
7. In the result, I pass the following:
ORDER
(i) The petition is allowed and disposed of in terms of the
decision of a Co-ordinate Bench of this Court in the case
of Ramachandra Reddy Ravi Kumar Vs. Deputy
Commissioner of Income-tax - W.P.No.17352/2022
and connected matters - dated 28.08.2025.
(ii) The impugned show cause notices and consequential
orders, notices etc., at Annexures-A, A1, A2, B, C, G,
G1, G2 and H dated 25.01.2024, 11.02.2024, 12.03.2024,
21.03.2024, 21.03.2024, 28.02.2025, 28.02.2025,
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28.02.2025 and 07.10.2025 respectively, are hereby
quashed.
(iii) Liberty is reserved in favour of the respondents -
Revenue to seek revival of this petition, subsequent to
disposal of the matters pending before the Apex Court
and all rival contentions between the parties in this regard
are kept open and no opinion is expressed on the same.
Sd/-
(S.R.KRISHNA KUMAR)
JUDGE
BMC
