- 1 - HC-KAR NC: 2025:KHC:46038 WP No. 26892 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 11TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 26892 OF 2024 (T-IT) BETWEEN: PISCES ESERVICES PRIVATE LIMITED HAVING ITS REGISTERED OFFICE AT 413, 3RD FLOOR REGENT INSIGNIA 1 7TH MAIN, 100 FEET ROAD, KORAMANGALA, S O BANGALORE SOUTH, BANGALORE – 560 034. REPRESENTED BY ITS AUTHORISED SIGNATORY / MANAGING DIRECTOR MR SOUMYA M (D/O MADHAVA MURTHY) REGISTERED UNDER INCORPORATED THE COMPANIES ACTS 2013. …PETITIONER (BY SRI. ANMOL ANAND AND SRI. GAUTHAM.R, ADVOCATES) AND: DEPUTY COMMISSIONER OF INCOME TAX CC/ACIT, CIRCLE5(1)(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU – 560 095. …RESPONDENT (BY SRI. M.THIRUMALESH, ADVOCATE) THIS W.P IS FILED UNDER ARTICLE 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE IMPUGNED ORDER DATED 30 -08-2024 ISSUED BY THE RESPONDENT UNDER SECTION 148A(D) OF THE INCOME TAX ACT, 1961 (ACT ) IN THE CASE OF THE PETITIONER FOR ASSESSMENT YEAR (AY) 2018-19, BEARING DOCUMENT IDENTIFICATION NUMBER ITBA/AST/F/148A/2024- 25/1068180123(1) (PRODUCED HEREWITH AS ANNEXURE-A) AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:46038 WP No. 26892 of 2024 CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks for the following reliefs:- “ I. Quash the impugned order dated: 30.08.2024 issued by the Respondent under Section 148A(d) of the Income Tax Act, 1961 (“ Act”) in the case of the Petitioner for Assessment Year (“AY”) 2018-19, bearing Document Identification Number ITBA/AST/F/148A/2024- 25/1068180123(1) (produced herewith as Annexure-A); and II. Quash the impugned notice dated: 30.08.2024 issued by the Respondent under Section 148 of the Act in the case of the Petitioner for AY2018-19, bearing Document Identification Number ITBA/AST/S/148_1 /2024/1068184371(1) (produced herewith as Annexure-B). III. Pass such other orders/directions as this Hon’ble Court may deem appropriate in the facts and circumstances of the case in hand in the interest of justice and equity.” 2. Heard learned counsel for the petitioner and learned counsel for the respondent and perused the material on record. 3. In addition to reiterating the various contentions urged in the petition and referring to the material on record, learned counsel for the petitioner invited my attention to the order of a Co- ordinate Bench of this Court in the case of Ramachandra Reddy - 3 - HC-KAR NC: 2025:KHC:46038 WP No. 26892 of 2024 Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order. 4. Per contra, learned counsel for the respondents - Revenue submits that there is no merit in the petition and that the same is liable to be dismissed. 5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under: "13. I, therefore, pass the following: O R D E R (i) The impugned show cause notices 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 these cases would stand quashed. - 4 - HC-KAR NC: 2025:KHC:46038 WP No. 26892 of 2024 (ii) Liberty is reserved to the respondents - revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of these petitions would become necessary." 6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of co-ordinate Bench of this Court in Ramachandra Reddy's case supra. 7. In the result, I pass the following: ORDER (i) The petition is allowed and disposed of in terms of the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025. - 5 - HC-KAR NC: 2025:KHC:46038 WP No. 26892 of 2024 (ii) The impugned order as well as notice, at Annexures- A and B both dated 30.08.2024 are hereby quashed. (iii) Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, subsequent to disposal of the matters pending before the Apex Court and all rival contentions between the parties in this regard are kept open and no opinion is expressed on the same. Sd/- (S.R.KRISHNA KUMAR) JUDGE Srl.