- 1 - HC-KAR NC: 2025:KHC:39705 WP No. 19345 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 19345 OF 2024 (T-IT) BETWEEN: LUBNA SHAH W/O SYED KALEEM SHAN AGED ABOUT 58 YEARS NO.1420 WYNHURST LANE VIENNA, VA 22182 USA PAN: GPBPS9748H REPRESENTED BY HER CONSTITUTED ATTORNEY ABUBAKER SIDDIQUE S/O S F M USMAN AGED ABOUT 36 YEARS NO.2, 3RD MAIN ROAD VASANTHNAGAR BENGALURU – 560 001. …PETITIONER (BY SMT. LOCHANA S.BABU, ADVOCATE) AND: 1. THE INCOME TAX OFFICER INTERNATIONAL TAXATION WARD 2(1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU – 560 095. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39705 WP No. 19345 of 2024 2. THE CHIEF COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION (SOUTH ZONE) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU – 560 095. …RESPONDENTS (BY SRI E.I.SANMATHI, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE ISSUED UNDER SECTION 148A(b) OF THE ACT DTD. 30.03.2024 OF THE ACT FOR THE ASSESSMENT YEAR 2017-18 BY THE R-1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)2023-24/1063698537(1) HEREIN MARKED AS ANNEXURE-A; QUASH THE ORDER DTD. 16.04.2024 PASSED UNDER SECTION 148A(d) OF THE ACT FOR THE ASSESSMENT YEAR 2017-18 BY THE R-1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A/2024- 25/1064136645(1) HEREIN MARKED AS ANNEXURE-A1; QUASH THE NOTICE DTD. 16.04.2024 ISSUED UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2017- 18 BY THE R-1 BEARING DIN AND NOTICE NO. ITBA/AST/S/148_1/2024-25/1064138204(1) HEREIN MARKED AS ANNX-A2. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39705 WP No. 19345 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of DIN and notices bearing No.ITBA/AST/F/148A(SNC)/2023-24/1063698537(1) dated 30.03.2024, ITBA/AST/S/148_1/2024-25/1064138204(1) dated 16.04.2024 and order No.ITBA/AST/F/148A/2024- 25/1064136645(1) dated 16.04.2024 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Smt. Lochana S. Babu, 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. In the light of the issue being similar and the reasons rendered therein becomes applicable to the case at hand, the - 4 - HC-KAR NC: 2025:KHC:39705 WP No. 19345 of 2024 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(SNC)/2023-24/1063698537(1) dated 30.03.2024, ITBA/AST/S/148_1/2024- 25/1064138204(1) dated 16.04.2024 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.: 2 Sl No.: 43