- 1 - HC-KAR NC: 2025:KHC:39255 WP No. 27678 of 2025 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. 27678 OF 2025 (T-IT) BETWEEN: 1. M/S. MAHALAKSHMI ENTERPRISES AN ASSOCIATION OF PERSONS HAVING ITS PLACE OF BUSINESS AT 50/1, 4TH FLOOR BANGALORE BAZAAR BENGALURU - 560 001 REP BY ITS MEMBER SHRI B T ASHOK AUTHORISED SIGNATORY 1998, 19TH B MAIN, 3RD CROSS J P NAGAR 2ND PHASE BENGALURU - 560 078 …PETITIONER (BY SMT. LOCHANA S. BABU, ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD 1(2)(1), BMTC BUILDING 80 FEET ROAD, 6TH BLOCK NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU - 560 095 Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39255 WP No. 27678 of 2025 2. THE INCOME TAX OFFICER (I AND CI) AMBAPURA, BERHAMPUR, PATHARA, ODISHA - 760 010 3. THE ADITIONAL JOINT COMMISSIONER OF INCOME TAX RANGE - 1 (1) BMTC BUILDING, 80 FEET ROAD 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU - 560 095 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE DATED 17.06.2025 ISSUED UNDER SECTION 148 OF THE ACT FOR THE AY 2021- 22 BY THE RESPONDENT NO. 1, HEREIN MARKED AS ANNEXURE - A. B) AND PASS SUCH OTHER ORDERS AND GRANT SUCH OTHER RELIEFS AS THIS HON'BLE HIGH COURT DEEMS FIT INCLUDING THE COST OF THIS WRIT PETITION IN THE INTEREST OF JUSTICE AND EQUITY. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39255 WP No. 27678 of 2025 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court, seeking the following prayer: "a) Issue a Writ of Certiorari or direction in the nature of a Writ of Certiorari quashing the notice dated 17.06.2025 issued under section 148 of the Act for the AY 2021-22 by the Respondent No. 1, herein marked as Annexure - A. b) And pass such other orders and grant such other reliefs as this Hon'ble High Court deems fit including the cost of this Writ Petition in the interest of justice and equity." 2. Heard Smt. Lochana S. Babu, 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 - 4 - HC-KAR NC: 2025:KHC:39255 WP No. 27678 of 2025 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 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE SJK CT-SG List No.: 12 Sl No.: 1