- 1 - HC-KAR NC: 2025:KHC:35156 WP No. 5801 of 2025 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. 5801 OF 2025 (T-IT) BETWEEN: 1. ORANGE COUNTY RESORTS AND HOTELS LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956, No. 11, RAMAPURAM HOUSE, RICHMOND ROAD, BENGALURU -560 025. REPRESENTED BY ITS CFO, SRI THOMAS CHERIAN RAMAPURAM, SON OF SRI CHERIAN THOMAS RAMAPURAM, AGED ABOUT 33 YEARS. …PETITIONER (BY SRI. MADHUSUDHAN U A, ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 5(1)(1), BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORMAGALA, BENGALURU - 560 095. 2. THE CHIEF COMMISSIONER OF INCOME TAX, BENGALURU -1, CENTRAL REVENUE BUILDING, QUEENS RAOD, BENGALURU - 560 001. …RESPONDENTS (BY SRI E I SANMATHI, ADVOCATE) Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:35156 WP No. 5801 of 2025 THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE DTD. 09.08.2024 ISSUED UNDER SECTION 148A(b) OF THE ACT FOR THE ASSESSMENT YEAR 2018-19 BY THE R-1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2024-25/1067510731(1) HEREIN MAKRED AS ANNX-A1 AND QUASH THE ORDER DTD. 21.08.2024 PASSED UNDER SECTION 148A(b) OF THE ACT FOR THE ASSESSMENT YEAR 2018-19 BY THE R-1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2024- 25/1067840963(1) HEREIN MARKED AS ANNX-A2 AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: 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)/2024-25/1067510731(1) dated 09.08.2024, ITBA/AST/F/148A/2024-25/1068212496(1) dated 31.08.2024, ITBA/AST/S/148_1/2024-25/1068213301(1) dated 31.08.2024 and order No.ITBA/AST/F/148A(SCN)/2024- 25/1067840963(1) dated 21.08.2024 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. - 3 - HC-KAR NC: 2025:KHC:35156 WP No. 5801 of 2025 2. Heard Sri Madhusudhan U.A., learned counsel for the petitioner and Sri E.I.Sanmathi, 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 notices bearing No. ITBA/AST/F/148A(SCN)/2024-25/1067510731(1) dated 09.08.2024, ITBA/AST/F/148A/2024- 25/1068212496(1) dated 31.08.2024, ITBA/AST/S/148_1/2024-25/1068213301(1) dated 31.08.2024 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. - 4 - HC-KAR NC: 2025:KHC:35156 WP No. 5801 of 2025 (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.: 415 CT.SM