- 1 - HC-KAR NC: 2025:KHC:36472 WP No. 11580 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28TH DAY OF AUGUST, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 11580 OF 2024 (T-IT) BETWEEN: M/S. JUNIPER TRUST A PRIVATE DISCRETIONARY TRUST ESTABLISHED UNDER THE INDIAN TRUSTS ACT 1882, REP BY ITS TRUSTEE, M/S VIDA TRUSTEES PVT LTD., REP BY ITS DIRECTOR SRI NANDAN LAXMAN SASTRY SON OF SRI LAXMAN SASTRY AGED ABOUT 44 YEARS, NO.23, NADATHUR PLACE 8TH MAIN, 3RD BLOCK JAYANAGAR BENGALURU 560 011. …PETITIONER (BY SRI. MADHUSUDHAN U A., ADVOCATE) AND: 1. ASSESSMENT UNIT /INCOME TAX OFFICER, INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E RAMP JAWARLAL NEHRU STADIUM DELHI 110003. 2. THE ASSISTANT COMMISSIONER OF INCOME Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:36472 WP No. 11580 of 2024 CIRCLE 7(1)(1), BENGALURU, BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE, KORAMANGALA BENGALURU 560 095. …RESPONDENTS (BY SRI. E.I.SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO A) QUASH THE ASSESSMENT ORDER DATED 28/03/2024 PASSED UNDER SECTION 147 RWS 144B OF THE ACT FOR THE ASSESSMENT YEAR 2018-19 BY THE R1 BEARING DIN NO. ITBA/AST/S/147/2023-24/1063534998(1) HEREIN MARKED AS ANNEXURE-A1 AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/AST/S/156/2023- 24/1063535126(1) dated 28.03.2024, ITBA/PNL/S/270A/2023- 24/1063535116(1) dated 28.03.2024, ITBA/AST/F/148A(SCN)/2021-22/1041327882(1) dated 23.03.2022, ITBA/AST/S/148_1/2022-23/1042635939(1) - 3 - HC-KAR NC: 2025:KHC:36472 WP No. 11580 of 2024 dated 07.04.2022, ITBA/AST/F/143(2)_5/2023- 24/1053585959(1) dated 07.06.2023, computation sheet No.ITBA/AST/S/185/2023-24/1063535100(1) dated 28.03.2024 and order Nos.ITBA/AST/S/147/2023- 24/1063534998(1) dated 28.03.2024, ITBA/AST/F/148A/2022- 23/1042635720(1) dated 07.04.2022 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Madhusudhan U.A., learned counsel for the petitioner and Sri E.I.Sanmathi, 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 petition deserves to be disposed on the same lines. Therefore, I pass the following: - 4 - HC-KAR NC: 2025:KHC:36472 WP No. 11580 of 2024 ORDER (i) The impugned notices bearing No. ITBA/AST/S/156/2023-24/1063535126(1) dated 28.03.2024, ITBA/PNL/S/270A/2023- 24/1063535116(1) dated 28.03.2024, ITBA/AST/F/148A(SCN)/2021-22/1041327882(1) dated 23.03.2022, ITBA/AST/S/148_1/2022- 23/1042635939(1) dated 07.04.2022, ITBA/AST/F/143(2)_5/2023-24/1053585959(1) dated 07.06.2023, computation sheet No.ITBA/AST/S/185/2023-24/1063535100(1) dated 28.03.2024 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. - 5 - HC-KAR NC: 2025:KHC:36472 WP No. 11580 of 2024 (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.: 1 Sl No.: 370