- 1 - HC-KAR NC: 2025:KHC:35674 WP No. 21927 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. 21927 OF 2024 (T-IT) BETWEEN: 1. UNIVERSAL POWER TRANSFORMERS PVT LTD., A PRIVATE LIMITED COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956, No.770, 12TH MAIN ROAD 100 FEET ROAD, HAL II STAGE, INDIRANAGAR, BENGALURU - 560 037. REP BY ITS MANAGING DIRECTOR SRI DHRUVA TALWALKAR SON OF SRI PRAFULLA TALWALKAR, AGED ABOUT 55 YEARS. …PETITIONER (BY SRI. SHREEHARI, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7 (1) (1) BENGALURU BMTC BUILDING, 80FT ROAD, NEAR KHB GAMES VILLAGE, 6TH BLOCK,, KORAMANGALA, BENGALURU - 560 095. 2. PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KARNATAKA AND GOA,, BENGALURU, CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU-560 001. AN AUTHORITY UNDER SECTION 116 OF THE INCOME TAX ACT, 19061. Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:35674 WP No. 21927 of 2024 3. ASSESSMENT UNIT A UNIT CREATED UNDER SECTION 144B, OF THE INCOME TAX ACT, 1961, ROOM NO.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM DELHI - 110 003. REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC). 4. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC) A CENTRE DESCRIBED UNDER SECTION 144B, OF THE INCOME TAX ACT, 1961, ROOM No.401, 2ND FLOOR, E-RAMP, JAWAHARLAL NEHRU STADIUM, DELHI-110 003. REP. BY PR. CHIEF COMMISSIONER, INCOME TAX (NEAC) …RESPONDENTS (BY SRI M THIRUMALESH, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR ANY OTHER SUITABLE WRIT FOR QUASHING OF THE DIGITALLY SIGNED AND ELECTRONICALLY COMMUNICATED NOTICE U/S 148A(B) OF THE INCOME TAX ACT, 1961 DATED 22/02/2023 ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2016-17 WHICH BEARS THE DIN 52 ITBA/AST/F/148A(SCN)/2022-23/1050010462(1) AND ENCLOSED AS ANNEXURE C1 AND ETC., - 3 - HC-KAR NC: 2025:KHC:35674 WP No. 21927 of 2024 THIS PETITION, COMING ON FOR PRELIMINARY HEARING, 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 DIN and notices bearing No.ITBA/AST/F/148A(SCN)/2022-23/1050010462(1) dated 22.02.2023, ITBA/AST/F/148A(SCN)/2022-23/1050048935(1) dated 23.02.2023, ITBA/AST/S/148_1/2022- 23/1051719633(1) dated 30.03.2023, ITBA/AST/S/61/2023- 24/1054069112(1) dated 30.06.2023, ITBA/AST/F/143(2)_5/2023-24/1054576174(1) dated 25.07.2023, ITBA/AST/S/156/2023-24/1060816835(1) dated 12.02.2024, ITBA/PNL/S/271(1)(b)/2023-24/1060816221(1) dated 12.02.2024, ITBA/PNL/S/271(1)(c)/2023- 24/1060816953(1) dated 12.02.2024, ITBA/PNL/S/271B/2023- 24/1060816951(1) dated 12.02.2024, ITBA/PNL/S/271F/2023- 24/1060816954(1) dated 12.02.2024, Computation of income bearing No.ITBA/AST/S/116/2023-24/1060816811(1) dated 12.02.2024 and order No.ITBA/AST/F/148A/2022- - 4 - HC-KAR NC: 2025:KHC:35674 WP No. 21927 of 2024 23/1051719552(1) dated 30.03.2023, ITBA/AST/S/147/2023- 24/1060816708(1) dated 12.02.2024, passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Shreehari, learned counsel for the petitioner and Sri M. Thirumalesh, 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: ORDER (i) The impugned DIN and notices bearing No. ITBA/AST/F/148A(SCN)/2022-23/1050010462(1) dated 22.02.2023, ITBA/AST/F/148A(SCN)/2022- 23/1050048935(1) dated 23.02.2023, - 5 - HC-KAR NC: 2025:KHC:35674 WP No. 21927 of 2024 ITBA/AST/S/148_1/2022-23/1051719633(1) dated 30.03.2023, ITBA/AST/S/61/2023- 24/1054069112(1) dated 30.06.2023, ITBA/AST/F/143(2)_5/2023-24/1054576174(1) dated 25.07.2023, ITBA/AST/S/156/2023- 24/1060816835(1) dated 12.02.2024, ITBA/PNL/S/271(1)(b)/2023-24/1060816221(1) dated 12.02.2024, ITBA/PNL/S/271(1)(c)/2023- 24/1060816953(1) dated 12.02.2024, ITBA/PNL/S/271B/2023-24/1060816951(1) dated 12.02.2024, ITBA/PNL/S/271F/2023- 24/1060816954(1) dated 12.02.2024 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. - 6 - HC-KAR NC: 2025:KHC:35674 WP No. 21927 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.: 390 CT.SM