- 1 - HC-KAR NC: 2025:KHC:34894 WP No. 18491 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. 18491 OF 2024 (T-IT) BETWEEN: 1. SKAVA ELECTRIC PRIVATE LIMITED 68, PRATHIBA INDUSTRIAL ESTATE, KANAKAPURA ROAD YELCHENAHALLI BENGALURU - 560 078 REP. BY ITS DIRECTOR SRI SHRENIK KAVEDIYA AGED ABOUT 47 YEARS, S/O SRI YASHWANTH RAJ REG. COMPANY REGISTERED UNDER SECTION 18 OF THE COMPANIES ACT, 2013. …PETITIONER (BY SRI. SHREEHARI, ADVOCATE) AND: 1. INCOME TAX OFFICER WARD 6(1)(1), BENGALURU THE JURISDICTIONAL ASSESSING OFFICER UNDER THE INCOME TAX ACT, 1961 BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE KORAMANGALA BENGALURU - 560 095. 2. PRINCIPAL COMMISSIONER OF INCOME TAX BENGLAURU -1, BENGALURU INCOME TAX AUTHORITY U/S 116 OF THE INCOME TAX ACT 1961 BMTC BUILDING 80 FT ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:34894 WP No. 18491 of 2024 KORAMANGALA BENGALURU - 560 095. 3. THE ASSESSMENT UNIT A UNIT CREATED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961, ROOM No.401, 2ND FLOOR, E RAMP JAWAHARLAL NEHRU STADIUM DELHI - 110 003 REP. BY PR. CHIEF COMMISSIONER OF INCOME TAX (NEAC). 4. NATIONAL FACELESS ASSESSMENT CENTRE A CENTRE DESCRIBED UNDER SECTION 144B OF THE INCOME TAX ACT, 1961 ROOM No.401, 2ND FLOOR, E RAMP JAWAHARLAL NEHRU STADIUM DELHI - 110 003. …RESPONDENTS (BY SRI Y V RAVI RAJ AND SRI M DILIP, ADVOCATES) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE NOTICE UNDER SECTION 148A(B) OF THE INCOME TAX ACT, 1961 DATED 09/03/2023 ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2019-20 WHICH BEARS THE DIN VIZ. ITBA/AST/F/148A(SCN)/2022- 23/1050564351(1) WHICH IS ENCLOSED AS ANNEXURE AND QUASHING THE ORDER UNDER SECTION 148A(D) OF THE INCOME TAX ACT, 1961 DATED 31/03/2023 ISSUED BY THE RESPONDENT NO. 1 FOR THE ASSESSMENT YEAR 2019-20 WHICH BEARS THE DIN VIZ. ITBA/AST/F/148A/2022- 23/1051764192(1) WHICH ENCLOSED AS ANNEXURE C AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:34894 WP No. 18491 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/AST/F/148A(SCN)/2022-23/1050564351(1) dated 09.03.2023, ITBA/AST/S/148_1/2022-23/1051779656(1) dated 31.03.2023, ITBA/AST/S/156/2023-24/1063097508(1) dated 21.03.2024, ITBA/PNL/S/270A/2023-24/1063097097(1) dated 21.03.2024, computation sheet bearing No.ITBA/AST/S/619/2023-24/1063097396(1) dated 21.03.2024 and orders No.ITBA/AST/F/148A/2022- 23/1051764192(1) dated 31.03.2023, ITBA/AST/S/147/2023- 24/1063096938(1) dated 21.03.2024 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Shreehari, learned counsel for the petitioner and Sri Y.V.Raviraj and Sri M. Dilip, learned counsel for the respondents. - 4 - HC-KAR NC: 2025:KHC:34894 WP No. 18491 of 2024 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 notices bearing No. ITBA/AST/F/148A(SCN)/2022-23/1050564351(1) dated 09.03.2023, ITBA/AST/S/148_1/2022- 23/1051779656(1) dated 31.03.2023, ITBA/AST/S/156/2023-24/1063097508(1) dated 21.03.2024, ITBA/PNL/S/270A/2023- 24/1063097097(1) dated 21.03.2024, computation sheet bearing No.ITBA/AST/S/619/2023- 24/1063097396(1) dated 21.03.2024 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. - 5 - HC-KAR NC: 2025:KHC:34894 WP No. 18491 of 2024 (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.: 384