- 1 - HC-KAR NC: 2025:KHC:39442 WP No. 6012 of 2023 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. 6012 OF 2023 (T-IT) BETWEEN: M/S. WAY2WEALTH SECURITIES PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 REPRESENTED BY ITS CHIEF FINANCIAL OFFICER SRI TERKUNJATTAYA KANNUR RAGHAVENDRA SON OF SRI T.K.RAMAKRISHNA RAO AGED ABOUT 54 YEARS RUKMINI TOWERS 3RD AND 4TH FLOOR NO.3/1 PLATFORM ROAD SHESHADRIPURA BENGALURU – 560 020. …PETITIONER (BY SRI MADHUSUDHAN U. A., ADVOCATE) AND: 1. CENTRAL BOARD OF DIRECT TAXES THROUGH THE CHAIRPERSON DEPARTMENT OF REVENUE MINISTRY OF FINANCE NORTH BLOCK NEW DELHI - 110 002. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39442 WP No. 6012 of 2023 2. THE DEPUTY COMMISSIONER OF INCOME TAX, CENRTAL CIRCLE - 1(3) CENTRAL AVENUE BUILDING QUEEN’S ROAD BENGALURU - 560 001. 3. THE DIRECTOR GENERAL INCOME TAX (INV.), CENTRAL REVENUE BUILDING QUEEN’S ROAD BENGALURU - 560 001. …RESPONDENTS (BY SRI Y.V.RAVIRAJ AND M.DILIP, ADVOCATES) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE NOTICE ISSUED UNDER SECTION 148A(B) OF THE ACT DTD 26.05.2022 OF THE ACT FOR THE ASSESSMENT YEAR 2014-15 BY THE R-2 BEARING DIN AND NOTICE NO. ITBA/COM/M/17/2022-23/1043186690(1) HEREIN MARKED AS ANNX-A1; QUASHING THE ORDER DTD 25.07.2022 PASSED UNDER SECTION 148A(D) OF THE ACT FOR THE ASSESSMENT YEAR 2014-15 BY THE R-2 BEARING DIN AND NOTICE NO.ITBA/COM/F/17/2022-23/1044051790(1) HEREIN MARKED AS ANNX-A2.QUASHING THE NOTICE DTD 25.07.2022 ISSUED UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2014-15 BY THE RESPONDENT -2 BEARING DIN AND NOTICE NO.ITBA/AST/M/148_1/2022-23/1044061425(1) HEREIN MARKED AS ANNX-A3; THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39442 WP No. 6012 of 2023 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/COM/M/17/2022- 23/1043186690(1) dated 26.05.2022, ITBA/AST/M/148_1/2022-23/1044061425(1) dated 25.07.2022 and order No.ITBA/COM/F/17/2022-23/1044051790(1) dated 25.07.2022 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 Y.V.Raviraj and Sri M. Dilip, 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 - 4 - HC-KAR NC: 2025:KHC:39442 WP No. 6012 of 2023 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned bearing No.ITBA/COM/M/17/2022- 23/1043186690(1) dated 26.05.2022 and ITBA/AST/M/148_1/2022-23/1044061425(1) dated 25.07.2022 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. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be - 5 - HC-KAR NC: 2025:KHC:39442 WP No. 6012 of 2023 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 324