- 1 - HC-KAR NC: 2025:KHC:39697 WP No. 29612 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. 29612 OF 2024 (T-IT) BETWEEN: M/S. ALGONOMY SOFTWARE PRIVATE LIMITED 40/4 LAVELLE ROAD, BENGALURU – 560 001, KARNATAKA (REPRESENTED BY ITS VP-FINANCE S/O MADHAD KHEMKA AGED ABOUT 56 YEARS) COMPANY INCORPORATED UNDER COMPANIES ACT, 1956. …PETITIONER (BY SMT. GEETHA RANI K., ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1)(1) BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU – 560 095. 2. THE ADDITIONAL/JOINT/DEPUTY/ ASSISTANT COMMISSIONER OF INCOME TAX, INCOME-TAX OFFICER, NATIONAL FACELESS-ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MINISTRY OF FINANCE, ROOM NO.401, 2ND FLOOR, E-RAMP, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39697 WP No. 29612 of 2024 JAWAHARLAL NEHRU STADIUM, DELHI – 110 003. …RESPONDENTS (BY SRI M.DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH AS FAR AS THE PETITIONER IS CONCERNED BY AN APPROPRIATE WRIT OR ORDER IN THE NATURE OF CERTIORARI OR OTHER WISE THE IMPUGNED ORDER DTD 31.08.2024 ISSUED BY THE LEARNED FIRST RESPONDENT UNDER SECTION 148A(d) VIDE DIN ITBA/AST/F/148A/2024-25/1068215001(1) FOR AY 2018- 19 ENCLOSED IN ANNEXURE-A; QUASH AS FAR AS THE PETITIONER IS CONCERNED BY AN APPROPRIATE WRIT OR ORDER IN THE NATURE OF CERTIORARI OR OTHERWISE THE IMPUGNED NOTICE U/S 148 DTD 31.08.2024 FOR THE REASSESSMENT OF INCOME ISSUED BY THE LEARNED FIRST RESPONDENT VIDE DIN ITBA/AST/S/148_1/2024- 25/1068215820(1) FOR THE AY 2018-19 ENCLOSED IN ANNEXURE-B. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39697 WP No. 29612 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notice bearing No.ITBA/AST/S/148_1/2024- 25/1068215820(1) dated 31.08.2024 and order No.ITBA/AST/F/148A/2024-25/1068215001(1) dated 31.08.2024 passed by the respondents – Revenue under Sections 148 and 148A(d) of the Income Tax Act, 1961. 2. Heard Smt. Geetha Rani K., learned counsel for the petitioner 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 petition deserves to be disposed on the same lines. Therefore, I pass the following: - 4 - HC-KAR NC: 2025:KHC:39697 WP No. 29612 of 2024 ORDER (i) The impugned notice bearing No. ITBA/AST/S/148_1/2024-25/1068215820(1) dated 31.08.2024 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. (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.: 2 Sl No.: 56