- 1 - HC-KAR NC: 2025:KHC:38008 WP No. 24800 of 2022 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 24800 OF 2022 (T-IT) BETWEEN: M/S SOWPARNIKA PROJECTS AND INFRASTRUCTURE PRIVATE LTD., REP BY ITS DIRECTOR SRI S SREENIVASAN, S/O SRI SUBRAMANIAM, 750, C BLOCK, 1ST MAIN ROAD, AECS, KUNDALAHALLI LAYOUT, BENGALURU - 560037 (A COMPANY REGISTERED UNDER COMPANIES ACT 1956) …PETITIONER (BY SRI. ANNAMALAI S., ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1(3) CENTRAL REVENUE BUILDING QUEENS ROAD, BENGALURU - 560001 2. PRINCIPA COMMISSIONER OF INCOME TAX CENTRAL REVENUE BUILDING QUEENS ROAD BENGALURU - 560001 3. JOINT COMMISSIONER OF INCOME TAX JCIT (OSD) CENTRAL CIRCLE 1(3) BLR Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:38008 WP No. 24800 of 2022 CENTRAL REVENUE BUILDING QUEENS ROAD BENGALURU - 560001 …RESPONDENTS (BY SRI. Y V RAVI RAJ, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE ISSUED UNDER SECTION 148(b) OF THE ACT DATED 24.05.2022 OF THE ACT BEARING DIN AND NOTICE NO.ITBA/COM/M/17/2022.23/1043138084(1)ISSUED BY THE R1 FOR THE ASSESSMENT YEAR 2016.17 HEREIN MARKED AS ANNEXURE-A1. 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: “i) 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 24.05.2022 bearing DIN & Notice No. ITBA/COM/M/17/2022-23/1043138084(1). The copy of the notice issued by the Respondent No.1 for the assessment year 2016-17 herein marked as Annexure - A1. - 3 - HC-KAR NC: 2025:KHC:38008 WP No. 24800 of 2022 ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 148 of the Act dated 15.04.2021 bearing DIN & Notice No. The digitally ITBA/AST/S/148/2021-22/1032427074(1). The digitally signed notice issued by Respondent No. 3 for the assessment year 2016-17 herein marked as Annexure - A2. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 27.07.2022 passed under section 148A(d) of the Act bearing DIN & Order No. ITBA/COM/F/17/2022-23/1044183162(1) issued by the Respondent No. 1 for the assessment year 2016-17 herein marked as Annexure-A3. iv) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 27.07.2022 issued under section 148 of the Act bearing DIN & Notice No. AITBA/AST/M/148_1/ 2022-23/1044191413(1) issued by the Respondent No. 1 for the assessment year 2016-17 herein marked as Annexure - A4. v) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri Y.V.Raviraj, 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 - 4 - HC-KAR NC: 2025:KHC:38008 WP No. 24800 of 2022 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 notices 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. - 5 - HC-KAR NC: 2025:KHC:38008 WP No. 24800 of 2022 (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 BSV List No.: 1 Sl No.: 208