- 1 - HC-KAR NC: 2025:KHC:34800 WP No. 25404 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. 25404 OF 2024 (T-IT) BETWEEN: 1. M/S. HI-Q ELECTRONICS PRIVATE LIMITED (A PRIVATE LIMITED COMPANY INCORPORATED UNDER THE COMPANIES ACT 1956) No.693, 3RD FLOOR,, GEETHANJALI COMPLEX 15TH CROSS, JP NAGAR 2ND PHASE BENGALURU - 560 078., KARNATAKA REPRESENTED BY ITS DIRECTOR SHRI SENDYL VENKATACHALAM. …PETITIONER (BY SRI ASHOK A KULAKARNI, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3 (1) (1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU KARNATAKA - 560 095. 2. CHIEF COMMISSIONER OF INCOME TAX-1 CR BUILDING QUEEN'S ROAD, BENGALURU KARNATAKA - 560 001. …RESPONDENTS (BY SRI M THIRUMALESH, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:34800 WP No. 25404 of 2024 QUASH DIRECTION IN THE NATURE OF CERTIORARI THE NOTICE U/S 148A(b) OF THE ACT DTD. 22.03.2024 FOR THE AY 2017-18 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2023-24/1063189472(1) IN ANNEXURE-G ISSUED BY THE R-1 AS UNLAWFUL AND ILLEGAL ALONG WITH THE ATTENDANT ACTIONS AND QUASH, DIRECTION IN THE NATURE OF CERTIORARI THE ORDER PASSED 148A(d) OF THE ACT BY THE R-1 DTD 05.04.2024 FOR THE AY 2017-18 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A/2024-25/1063936968(1) IN ANNEXURE-H ISSUED BY THE R-1 AS UNLAWFUL AND ILLEGAL ALONG WITH THE ATTENDANT ACTIONS AND ETC., 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 is before this Court seeking the following prayer: “a. Quash by an order, writ, or direction in the nature of Certiorari the Notice u/s 148A(b) of the Act dated 22.03.2024 for the AY 2017-18 bearing DIN and Notice No. number ITBA/AST/F/148A(SCN)/2023- 24/1063189472(1) in Annexure "G" issued by the 1st Respondent as unlawful and illegal along with the attendant actions. b. Quash by an order, writ, or direction in the nature of certiorari the Order passed 148A(d) of the Act by the 1st Respondent dated 05.04.2024 for the AY: 2017-18 bearing DIN & Notice No. ITBA/AST/F/148A/2024-25/1063936968(1) in Annexure "H" issued by the 1st Respondent as - 3 - HC-KAR NC: 2025:KHC:34800 WP No. 25404 of 2024 unlawful and illegal along with the attendant actions. c. Quash by an order, writ, or direction in the nature of Certiorari the Notice u/s 148 of the Act dated 05.04.2024 for the AY 2017-18 bearing DIN and Notice No. ITBA/AST/S/148_1/2024- 25/1063938802(1) in Annexure "J" issued by the 1st Respondent as unlawful and illegal along with the attendant actions. d. Grant such other relief that this Hon'ble Court may think fit including the cost of this petition in the interest of justice and equity.” 2. Heard Sri Ashok A. Kulakarni, 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: - 4 - HC-KAR NC: 2025:KHC:34800 WP No. 25404 of 2024 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. (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.: 397 CT.SM