- 1 - HC-KAR NC: 2025:KHC:39228 WP No. 8148 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. 8148 OF 2024 (T-IT) BETWEEN: SRI SUMERU REALTY PRIVATE LIMITED, A PRIVATE LIMITED COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 AND HAVING ITS REGISTERED OFFICE AT 2ND FLOOR, SAMVIT, KANAKAPURA MAIN ROAD, UDAYAPURA, BENGALURU - 560082 (PAN: AAICS7169R) REPRESENTED BY ITS MANAGING DIRECTOR, SHRI NARENDRA SINGH LAMBA, S/O MAHAVIR SINGH LAMBA, AGED ABOUT 47 YEARS, OCCUPATION: MANAGING DIRECTOR, RESIDING AT VVMPV CAMPUS, ART OF LIVING INTERNATIONAL CENTRE, 21ST KM, KANAKAPURA ROAD, UDAYAPURA, BENGALURU - 560082. …PETITIONER (BY SRI. K.R.VASUDEVAN, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39228 WP No. 8148 of 2024 AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, DC/ACIT CIRCLE 6(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560095. 2. THE ASSESSMENT UNIT, INCOME TAX DEPARTMENT, 2ND FLOOR, JAWAHARLAL NEHRU STADIUM, NEW DELHI - 110003. 3. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX, RANGE 6, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560095. …RESPONDENTS (BY SRI.M.DILIP, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE FOLLOWING - ANNEXURE -B IMPUGNED NOTICE DATED 02.03.2023 ISSUED BY THE RESPONDENT NO.1 UNDER SECTION 148A (b) OF THE IT ACT FOR THE AY 2019-20 IN DIN AND NOTICE NO. ITBA/ASF/F/148A(SCN)/2022- 23/1050345726(1) AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39228 WP No. 8148 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 'B' Impugned notice dated 02.03.2023 issued by the Respondent No.1 under Section 148A(b) of the IT Act for the AY 2019-20 in DIN & Notice No.: ITBA/AST/F/148A(SCN)/2022-23/1050345726(1) ANNEXURE 'C' Impugned order dated 26.03.2023 passed by the Respondent No.1 under Section 148A(d) of the IT Act for the AY 2019-20 in DIN & Notice No.: ITBA/AST/F/148A/2022-23/1051338759(1) ANNEXURE 'D' Impugned notice dated 26.03.2023 issued by the Respondent No.1 under Section 148 of the IT Act for the AY 2019-20 in DIN & Notice No.: ITBA/AST/S/148_1/2022-23/1051338907(1) ANNEXURE 'G' Impugned show cause notice dated 04.03.2024 issued by the Respondent No.2 under Section 144 of the IT Act for the AY 2019-20 in DIN: ITBA/AST/F/144(SCN)/2023-24/1061970267(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.” - 4 - HC-KAR NC: 2025:KHC:39228 WP No. 8148 of 2024 2. Heard Sri.K.R.Vasudevan, learned counsel for the petitioner and Sri M. Dilip, 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 show cause notice 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 - 5 - HC-KAR NC: 2025:KHC:39228 WP No. 8148 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 in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE CBC List No.: 2 Sl No.: 17