- 1 - HC-KAR NC: 2025:KHC:39205 WP No. 11126 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. 11126 OF 2024 (T-IT) BETWEEN: RAJENDRA KUMAR SHREEMAL, [FORMER DIRECTOR OF ERSTWHILE QUALITY ENGINEERING AND SOFTWARE TECHNOLOGIES EUROPE LTD (DISSOLVED)] RESIDING AT 1 RHU CROSS, NO.11-05, COSTA RHU, SINGAPORE-437431, AGED ABOUT 53 YEARS, SON OF GHEWAR CHAND SHREEMAL. …PETITIONER (BY SMT. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX, ASMNT CIRCLE 2(1), BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE-560095. 2. THE COMMISSIONER OF INCOME TAX - (INTERNATIONAL TAXATION) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39205 WP No. 11126 of 2024 BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE-560095. …RESPONDENTS (BY SRI. Y.V.RAVIRAJ, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE ORDER DATED 29.04.2022 BEARING NO.ITBA/COM/F/17/2022- 23/1042905984(1) (ANNEXURE-D) PASSED BY THE 1ST RESPONDENT UNDER SECTION 148A(d) OF THE ACT, FOR THE ASSESSMENT YEAR 2018-19; QUASHING THE NOTICE DATED 29.04.2022 BEARING ITBA/COM/F/17/2022-23/1042907347(1) (ANNEXURE-E) ISSUED BY THE 1ST RESPONDENT UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2018- 19 AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39205 WP No. 11126 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “(a) quashing the order dated 29.04.2022 bearing No.ITBA/COM/F/17/2022-23/1042905984(1) (Annexure D) passed by the 1st Respondent under section 148A(d) of the Act, for the Assessment Year 2018-19; (b) quashing the notice dated 29.04.2022 bearing ITBA/COM/F/17/2022-23/1042907347(1) (Annexure E) issued by the 1st Respondent under section 148 of the Act for the Assessment Year 2018-19; and (c) Quashing of the draft assessment order dated 05.02.2024 bearing No.ITBA/AST/F/144C/2023- 24/1060510467(1) (Annexure J) issued by the 1st Respondent under section 144C(1) of the Act for the Assessment Year 2018-19; (d) pass such other or further orders as this Hon'ble Court may deem fit in the facts and circumstances of the case, in the interests of justice and equity.” 2. Heard Smt.Tanmayee Rajkumar, learned counsel for the petitioner and Sri.Y.V.Raviraj, learned counsel for the respondents. - 4 - HC-KAR NC: 2025:KHC:39205 WP No. 11126 of 2024 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 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:39205 WP No. 11126 of 2024 (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 CBC List No.: 2 Sl No.: 22