- 1 - HC-KAR NC: 2025:KHC:37475 WP No. 5046 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 5046 OF 2025 (T-IT) BETWEEN: CONDUENT BUSINESS SERVICES INDIA LLP., (FORMERLY XEROX BUSINESS SERVICES INDIA LLP), UNIT-A, 5TH FLOOR AVIATOR BUILDING, ASCENDAS ITPB SEZ WHITEFIELD ROAD BENGALURU, KARNATAKA, INDIA – 560 066 REPRESENTED BY ITS PARTNER MR. ANITUS NIRANJAN INCORPORATED, REFER RULE – 20 OF THE LLP RULES, 2009. …PETITIONER (BY MISS TANMAYEE RAJKUMAR, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37475 WP No. 5046 of 2025 AND: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(1)(1), BENGALURU CENTRAL REVENUE BUILDING QUEENS ROAD, BENGALURU – 560 001. 2. CHIEF COMMISSIONER OF INCOME TAX - 1 BMTC BUILDING, 6TH BLOCK 80 FEET ROAD, KORAMANGALA BENGALURU – 560 095. …RESPONDENTS (BY SRI E.I.SANMATHI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE DTD. 31.08.2024 BEARING NO. ITBA/AST/S/148- 1/2024-25/1068217805(1) (ANNX-P) ISSUED BY THE R-1 UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2018-19 AND ETC., THIS PETITION, COMING ON FOR FINAL HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:37475 WP No. 5046 of 2025 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayer: “ “a) Quashing the notice dated 31.08.2024 bearing no. ITBA/AST/S/148_1/2024-25/1068217805(1) (Annexure 'P') issued by the 1st Respondent under Section 148 of the Act for the assessment year 2018-19; b) Quash the order dated 31.08.2024 bearing no. ITBA/AST/F/148A/2024-25/1068216306(1) (Annexure 'N') passed by the 1st Respondent under Section 148A(d) of the Act for the assessment year 2018-19; and c) pass such other or further orders as this Hon'ble Court may deem fit in the facts and circumstances of the case, in the interests of justice and equity.” 2. Heard Ms. Tanmayee Rajkumar, 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 - HC-KAR NC: 2025:KHC:37475 WP No. 5046 of 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 show cause notice issued by the jurisdictional Assessing Officer outside the scope of Section 151-A 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:37475 WP No. 5046 of 2025 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 70 CT:SS