- 1 - HC-KAR NC: 2025:KHC:39315 WP No. 33305 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. 33305 OF 2024 (T-IT) BETWEEN: M/S HASSAN MANGALORE RAIL DEVELOPMENT COMPANY LIMITED 7TH FLOOR, MSIL HOUSE 36, CUNNINGHAM ROAD BENGALURU- 560052. (A COMPANY LIMITED UNDER REGISTERED COMPANIES ACT, 1956) REP BY ITS COMAPNY SECRETARY SHRI SHARATH BABU R M 3763 4TH A MAIN E BLOCK 2ND STAGE RAJAJINGARA BENGALURU- 560021 …PETITIONER (BY SRI. RAVI SHANKAR S V.,ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(1) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39315 WP No. 33305 of 2024 BMTC BUILDING 80 FEET ROAD 6TH BLCOK NEAR KHB GAMES VILLAGEKORAMANGALA BENGALURU- 560095 2. THE CHIEF COMMISSIONER OF INCOME TAX-1, CENTRAL REVENUE BUIDLING QUEENS ROAD BENGALURU- 560001 …RESPONDENTS (BY SRI. M.THIRUMALESH, ADVOCATE) THIS W.P. 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. 09.08.2024 FOR THE ASSESSMENT YEAR 2018-19 BY THE R-1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2024- 25/1067510428(1) HEREIN MARKED AS ANNX-A. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39315 WP No. 33305 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “a) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 148A(b) of the Act dated 09.08.2024 for the assessment year 2018-19 by the Respondent No. 1 bearing DIN & Notice No. ITBA/AST/F/148A(SCN)/2024- 25/1067510428 (1) herein marked as Annexure - A. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 30.08.2024 passed under section 148A(d) of the Act for the assessment year 2018-19 by the Respondent No. 1 bearing DIN & Notice No. ITBA/AST/F/148A/2024- 25/1068188025(1) herein marked as Annexure - A1. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 30.08.2024 issued under section 148 of the Act for the assessment year 2018- 19 by the Respondent No. 1 bearing DIN Notice No. & ITBA/AST/S/148_1/2024- 25/1068188355 (1) herein marked as Annexure - A2. d) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." - 4 - HC-KAR NC: 2025:KHC:39315 WP No. 33305 of 2024 2. Heard Shri Ravishankar S.V., learned counsel appearing for the petitioner and Shri M. Thirumalesh, learned counsel appearing 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 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, - 5 - HC-KAR NC: 2025:KHC:39315 WP No. 33305 of 2024 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.: 2 Sl No.: 65