- 1 - HC-KAR NC: 2025:KHC:39307 WP No. 32637 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. 32637 OF 2024 (T-IT) BETWEEN: M/S AKARSH RESIDENCE PVT. LTD., NO 2.4, LANGFORD GARDEN RICHMOND TOWND BENGALURU - 560 025 (UNDER REGISTERED COMPANIES ACT 1956) REPRESENTEDBY B.M. JAYESHANKAR DIRECTOR SON OF B.M. MADAIAH NO 2.4, LANGFORD GARDEN RICHMOND TOWN BENGALURU - 560 025 …PETITIONER (BY SRI. RAVI SHANKAR S.V, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39307 WP No. 32637 of 2024 AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(1) C R BULIDING, QUEENS ROAD, SHIVAJIGNAGAR, BENGALURU - 560 001. 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) C R BUILDING, QUEESN ROAD, SHVIAJINAGAR, BENGALURU - 560 001 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS WP IS FILED UNDE ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE SHOW CAUSE NOTICE DATED 31/03/2024 ISSUED UNDER SECTION 148(B) OF THE INCOME TAX ACT, 1961 (THE ACT) FOR THE ASSESSMENT YEAR 2020-21 BY THE RESPONDENT NO. 1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2023- 24/1063752091(1) HEREIN MARKED AS ANNEXURE-A AND ETC., - 3 - HC-KAR NC: 2025:KHC:39307 WP No. 32637 of 2024 THIS PETITION, COMING ON FOR PRELIMINARY HEARING, 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 prayers: “a) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the show cause notice dated 31.03.2024 issued under section 148A(b) of the Income Tax Act, 1961 ("the Act") for the assessment year 2020-21 by the Respondent No. 1 bearing DIN & Notice No. ITBA/AST/F/148A(SCN)/2023- 24/1063752091(1) herein marked as Annexure - A. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the unsigned sanction dated 18.04.2024 accorded under section 151 of the Act for the assessment year 2020-21 by the Respondent No. 2 bearing DIN & Notice No. ITBA/AST/S/118/2024-25/1064198345(1) herein marked as Annexure - A1. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 18.04.2024 passed under section 148A(d) of the Income Tax Act, 1961 ("the Act") for the assessment year 2020-21 by the Respondent No. 1 bearing DIN & Notice No. ITBA/AST/F/148A/2024-25/1064198431(1) herein marked as Annexure - A2. - 4 - HC-KAR NC: 2025:KHC:39307 WP No. 32637 of 2024 d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 18.04.2024 issued under section 148 of the Act for the assessment year 2020- 21 by the Respondent No. 1 bearing DIN & Notice No. ITBA/AST/S/148_1/2024- 25/1064199075(1) herein marked as Annexure - АЗ. e) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Shri Ravishankar S.V., learned counsel appearing for the petitioner and Shri M. Dilip, 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: - 5 - HC-KAR NC: 2025:KHC:39307 WP No. 32637 of 2024 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, 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.: 61 CT: BHK