- 1 - HC-KAR NC: 2025:KHC:39279 WP No. 28474 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. 28474 OF 2025 (T-IT) BETWEEN: 1. M/S SOURABH MINES PRIVATE LIMITED A PRIVATE LIMITED COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 REPRESENTED BY ITS MANAGING DIRECTOR CHINNASWAMY CHANNASANDRA GIRIRAJA GOWDA SON OF LATE SRI. GIRIRAJA GOWDA C AGED ABOUT 73 YEARS, NO. 490, 3RD FLOOR SRI VENKATESHWARA MANOR, 80FT ROAD HMT LAYOUT, R.T. NAGAR BANGALORE - 560 032, KARNATAKA …PETITIONER (BY SRI. ANNAMALAI S., ADVOCATE) AND: 1. THE INCOME TAX OFFICER WARD-6(1)(1), BANGALORE, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39279 WP No. 28474 of 2025 BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095, KARNATAKA …RESPONDENT (BY SRI. M. DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO I) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE ISSUED UNDER SECTION 148A(1) OF THE ACT DATED 24.03.2025 ISSUED BY THE RESPONDENT BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)-1/2024-25/1074957574(1) AND THE SAME IS REFERRED AS ANNEXURE A1. II) ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE ORDER PASSED UNDER SECTION 148A(3) OF THE ACT DATED 29.06.2025 BY THE RESPONDENT BEARING DIN AND NOTICE NO. ITBA/AST/F/148A/2025- 26/1077986072(1) AND THE SAME IS REFERRED AS ANNEXURE -A2 AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39279 WP No. 28474 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 notice issued under section 148A(1) of the Act dated 24.03.2025 issued by the Respondent bearing DIN & Notice No. ITBA/AST/F/148A(SCN)_1/2024- 25/1074957574(1) and the same is referred as Annexure 'A1'. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed under section 148A(3) of the Act dated 29.06.2025 by the Respondent bearing DIN & Notice No. ITBA/AST/F/148A/2025-26/1077986072(1) and the same is referred as Annexure 'A2'. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 148 of the Act dated 29.06.2025 bearing DIN & Notice No. ITBA/AST/S/148_1/2025- 26/1077986094(1) issued by the Respondent and the same is referred as Annexure 'A3'. iv) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri M. Dilip, learned counsel for the respondent. - 4 - HC-KAR NC: 2025:KHC:39279 WP No. 28474 of 2025 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 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. - 5 - HC-KAR NC: 2025:KHC:39279 WP No. 28474 of 2025 (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.: 27