- 1 - HC-KAR NC: 2025:KHC:39438 WP No. 3694 of 2023 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. 3694 OF 2023 (T-IT) BETWEEN: ALPHAGREP SECURITIES PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 REPRESENTED BY ITS AUTHORISED SIGNATORY SRI MANJUNATHA K. M., S/O K.MANOHAR AGED ABOUT 40 YEARS NO.2 , 7TH FLOOR, BRABOURNE ROAD GOVIND BHAVAN, KOLKATA – 700 001 ALSO AT NO.107/3, 2ND FLOOR 80 FEET ROAD, 4TH BLOCK KORAMANGALA BENGALURU – 560 034. …PETITIONER (BY SRI MADHUSUDHAN U. A., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE - 1(3), BENGALURU Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39438 WP No. 3694 of 2023 CENTRAL REVENUE BUILDING QUEEN’S ROAD BENGALURU – 560 001. 2. THE DIRECTOR GENERAL INCOME TAX (INV.), CENTRAL REVENUE BUILDING QUEEN’S ROAD BENGALURU – 560 001. …RESPONDENTS (BY SRI E.I.SANMATHI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE ISSUED UNDER SECTION 148(A)(b) OF THE ACT DTD 31.05.2022 OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R-1 BEARING DIN AND NOTICE NO.ITBA/COM/F/17/2022-23/1043274715(1) VIDE ANNX-A1; QUASH THE ORDER DTD 26.07.2022 PASSED UNDER SECTION 148(A)(d) OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R-1 BEARING DIN AND NOTICE NO.ITBA/COM/F/17/2022-23/1044124036 (1) VIDE ANNX-A2; QUASH THE NOTICE DTD 26.07.2022 ISSUED UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R-1 BEARING DIN AND NOTICE NO.ITBA/AST/M/148_1/2022- 23/1044126121(1) VIDE ANNX-A3. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39438 WP No. 3694 of 2023 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/COM/F/17/2022- 23/1043274715(1) dated 31.05.2022, ITBA/AST/M/148_1/2022-23/1044126121(1) dated 26.07.2022 and order No.ITBA/COM/F/17/2022-23/1044124036(1) dated 26.07.2022 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Annamalai S., learned counsel for the petitioner and Sri Y.V.Raviraj 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 - HC-KAR NC: 2025:KHC:39438 WP No. 3694 of 2023 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/COM/F/17/2022-23/1043274715(1) dated 31.05.2022 and ITBA/AST/M/148_1/2022- 23/1044126121(1) dated 26.07.2022 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. (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:39438 WP No. 3694 of 2023 (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.: 322 CT:SS