- 1 - HC-KAR NC: 2025:KHC:34941 WP No. 18703 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 4TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 18703 OF 2025 (T-IT) BETWEEN: UNITED SPIRITS LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 AND HAVING ITS OFFICE AT UB TOWERS, NO.24, VITTAL MALLYA ROAD, BENGALURU – 560 001 REPRESENTED HEREIN BY ITS JAYATHEERTHA KULKARNI GENERAL MANAGER – TAXATION. …PETITIONER (BY MISS. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(1) CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU – 560 001. 2. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, CENTRAL CIRCLE RANGE-2 CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU – 560 001. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:34941 WP No. 18703 of 2025 3. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, CENTRAL CIRCLE RANGE-2 CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU – 560 001. …RESPONDENTS (BY SRI K.HEMA KUMAR, AGA) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE ORDER DATED 24.03.2025 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A/2024-25/1074942629(1) (ANNEXURE C) PASSED BY THE 1ST RESPONDENT UNDER SECTION 148A(3) OF THE ACT FOR THE ASSESSMENT YEAR 2019-20; B) QUASHING OF THE NOTICE DATED 30.03.2025 BEARING DIN AND NOTICE NO.ITBA/AST/S/148_1/2024-25/1075275408(1) (ANNEXURE E) PASSED BY THE 1ST RESPONDENT UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2019-20. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayer: a) Quashing the order dated 24.03.2025 bearing DIN and Notice No. ITBA/AST/F/148A/2024- 25/1074942629(1) (Annexure C) passed by the 1st Respondent under Section 148A(3) of the Act for the assessment year 2019-20; b) Quashing of the notice dated 30.03.2025 bearing DIN and Notice No. ITBA/AST/S/148_1/2024- - 3 - HC-KAR NC: 2025:KHC:34941 WP No. 18703 of 2025 25/1075275408(1) (Annexure E) passed by the 1st Respondent under Section 148 of the Act for the assessment year 2019-20; c) pass such other or further orders as this Hon'ble Court may deem fit in the facts and circumstances of the case, in the interests of justice and equity.” 2. Heard Miss Tanmayee Rajakumar, learned counsel for the petitioner and Sri K Hema Kumar, learned Additional Government Advocate 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 151-A of the Act stand obliterated. All - 4 - HC-KAR NC: 2025:KHC:34941 WP No. 18703 of 2025 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 BKP List No.: 1 Sl No.: 93