- 1 - HC-KAR NC: 2025:KHC:39313 WP No. 34193 of 2024 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. 34193 OF 2024 (T-IT) BETWEEN: M/S UNISHIRE SKYSCAPES LLP NO 42, CASTLE STREET, ASHOK NAGAR, CMP CENTRE AND SCHOOL BENGALURU- 560025 REPRESENTED BY ITS AUTHORIZED REPRESENTATIVE/ MANAGER, PRATIK K MEHTA, 301, MOUDGAL HOMES, NO 6, UPPER PIPELINE ROAD, KUAMRA PARK WEST, BENGALURU- 560020. INCORPORATED UNDER PARTNERSHIP ACT, 2008. …PETITIONER (BY SMT. LOCHANA S BABU, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39313 WP No. 34193 of 2024 INCOME TAX, CENTRAL CIRCLE - 2(4) CENTRAL REVENUE BUILDING QUEENS ROAD, BENGALURU- 560001 2. THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) CENTRAL REVENUE BUILDING QUEENS ROAD, BENGALURU- 560001 …RESPONDENTS (BY SRI. M.DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE ISSUED UNDER SECTION 148A(b) OF THE ACT DTD. 31.01.2023 FOR THE AY 2019-20 BY THE R-1 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2022- 23/1049289878(1) HEREIN MARKED AS ANNX-A., AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN B GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39313 WP No. 34193 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: “a) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice Issued under section 148A(b) of the Act dated 31.01.2023 for the AY 2019-20 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/F/148A(SCN)/2022- 23/1049289878(1) herein marked as Annexure - A. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 20.03.2023 passed under section 148A(d) of the Act for the AY 2019-20 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/F/148A/2022-23/1050976875(1) herein marked as Annexure - A1. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 20.03.2023 issued under section 148 of the Act for the AY 2019-20 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/148_1/2022-23/1050977172(1) herein marked as Annexure - A2. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 28.03.2024 passed under section 147 of the Act for the AY 2019-20 by the Respondent No.1 bearing DIN & Order No. - 4 - HC-KAR NC: 2025:KHC:39313 WP No. 34193 of 2024 ITBA/AST/S/147/2023-24/1063507871(1) herein marked as Annexure- А3. e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty show cause notice dated 28.03.2024 issued under section 270A of the Act for the AY 2019-20 by the Respondent No.1 bearing DIN & Notice No. ITBA/PNL/S/270A/2023- 24/1063507874(1) herein marked as Annexure - A4. f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty show cause notice dated 30.03.2024 issued under section 271AAC(1) of the Act for the AY 2019-20 by the Respondent No.1 bearing DIN & Notice No. ITBA/PNL/S/271AAC(1)/2023- 24/1063665097(1) herein marked as Annexure A5. g) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity." 2. Heard Smt. Lochana S. Babu, learned counsel appearing for the petitioner and Shri M. Dilip, learned counsel appearing for the respondents. 3. The grounds projected in the subject petition in support of the prayer quoted supra are identical to the ones - 5 - HC-KAR NC: 2025:KHC:39313 WP No. 34193 of 2024 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. - 6 - HC-KAR NC: 2025:KHC:39313 WP No. 34193 of 2024 (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 JY List No.: 2 Sl No.: 67