- 1 - HC-KAR NC: 2025:KHC:39262 WP No. 27681 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. 27681 OF 2025 (T-IT) BETWEEN: 1. ORACLE SOLUTION SERVICES (INDIA) PVT LTD A COMPANY INCORPORATED UNDER THE COMPANIES ACT 1956, REPRESENTED BY ITS AUTHORISED SIGNATORY SRI. UMA SHANKAR GAUTAM, SON OF LATE SRI. OM PRAKASH SHARMA, AGED ABOUT 49 YEARS, HAVING ITS REGISTERED OFFICE AT: BLOCK B LVL 4, NO. 169/1, ORACLE TECH HUB, MARTHAHALLI RING ROAD KADUBEESANHALLI, BELLANDUR, BANGALORE - 560 103. …PETITIONER (BY SRI. ANNAMALAI S., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 5(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39262 WP No. 27681 of 2025 BANGALORE - 560 095. 2. THE JOINT / ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 3(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE - 560 095. …RESPONDENTS (BY SRI. M. THIRUMALESH, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE IMPUGNED NOTICE ISSUED SECTION 148A (1) OF THE ACT DATED 25.03.2025 BY THE RESPONDENT NO. 1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)_1/2024-25/1074988859(1) FOR THE ASSESSMENT YEAR 2021-22 HEREIN MARKED AS ANNEXURE - A1 AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39262 WP No. 27681 of 2025 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court, seeking the following prayer: "i) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Impugned Notice issued Section 148A (1) of the Act dated 25.03.2025 by the Respondent No. 1 bearing DIN & Notice No. ITBA/AST/F/148A(SCN)_1/2024- 25/1074988859(1) for the assessment year 2021- 22 herein marked as Annexure - A1. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Impugned Order passed under Section 148A (3) dated 30.06.2025 by the Respondent No. 1 bearing DIN & Notice No. ITBA/AST/F/148A/2025- 26/1078037197(1) for the assessment year 2021- 22 herein marked as Annexure - A2. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Impugned Notice issued under Section 148 dated 30.06.2025 bearing DIN & Notice No. ITBA/AST/S/148_1/2025-26/1078037713(1) issued by the Respondent No. 1 for the assessment year 2021-22 herein marked as Annexure - АЗ. iv) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." - 4 - HC-KAR NC: 2025:KHC:39262 WP No. 27681 of 2025 2. Heard Sri Annamalai S., 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 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 - 5 - HC-KAR NC: 2025:KHC:39262 WP No. 27681 of 2025 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.: 5 Sl No.: 18