- 1 - HC-KAR NC: 2025:KHC:39703 WP No. 19010 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. 19010 OF 2024 (T-IT) BETWEEN: SAMPIGEHUTTY ESTATE PRIVATE LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 HAVING OFFICE AT NO. 2/23 1ST FLOOR, 12TH CROSS, SWIMMING POOL EXTENSION MALLESHWARAM BENGALURU – 560 003 REPRESENTED BY ITS DIRECTOR SURESH BABU. …PETITIONER (BY SMT. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. INCOME TAX OFFICER WARD 6(1)(1) - BANGALORE BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU – 560 095. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39703 WP No. 19010 of 2024 2. CHIEF COMMISSIONER OF INCOME TAX- 1 BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU – 560 095. …RESPONDENTS (BY SRI M.DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO A) QUASH THE ORDER DATED 15/04/2024 BEARING NO. ITBA/AST/F/148A/2024- 25/1064097118(1) (ANNEXURE-M) PASSED BY THE R1 UNDER SECTION 148A(d) OF THE ACT FOR THE ASSESSMENT YEAR 2017-18; B) QUASH OF THE NOTICE DATED 15/04/2024 BEARING NO. ITBA/AST/S/148_1/2024-25/1064097315(1) (ANNEXURE-N) PASSED BY THE R1 UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2017-18. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39703 WP No. 19010 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notice bearing No.ITBA/AST/S/148_1/2024- 25/1064097315(1) dated 15.04.2024 and order No.ITBA/AST/F/148A/2024-25/1064097118(1) dated 15.04.2024 passed by the respondents – Revenue under Sections 148 and 148A(d) of the Income Tax Act, 1961. 2. Heard Smt. Tanmayee Rajkumar, 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 - 4 - HC-KAR NC: 2025:KHC:39703 WP No. 19010 of 2024 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned notice bearing No. ITBA/AST/S/148_1/2024-25/1064097315(1) dated 15.04.2024 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.: 41