- 1 - HC-KAR NC: 2025:KHC:39698 WP No. 31969 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. 31969 OF 2024 (T-IT) BETWEEN: RNS INFRASTRUCTURE LIMITED (A PUBLIC LIMITED COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956) 7TH FLOOR, NAVEEN COMPLEX, 14 M.G.ROAD, BENGALURU, KARNATAKA – 560 001 REPRESENTED BY ITS MANAGING DIRECTOR SHRI NAVEEN SHETTY AGED ABOUT 56 YEARS. …PETITIONER (BY SRI ASHOK A.KULAKARNI, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(3) C.R.BUILDING, QUEEN’S ROAD, BENGALURU, KARNATAKA – 560 001. 2. DIRECTOR GENERAL OF INCOME TAX (INVESTIGATION), BENGALURU, C.R.BUILDING, QUEENS ROAD, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39698 WP No. 31969 of 2024 BENGALURU KARNATAKA - 560 001. …RESPONDENTS (BY SRI Y.V.RAVIRAJ, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH BY AN ORDER WRIT OR DIRECTION IN THE NATURE OF CERTIORARI THE ORDER U.S 148A(d) OF THE ACT DTD 29.08.2024 FOR AY 2018-19 BEARING DIN AND NOTICE NO ITBA/AST/F/148A/2024-25/1068139736(1) DTD 29.08.2024 PASSED BY THE R-1 IN ANNEXURE-E FOR BEING ERRONEOUS, UNLAWFUL ILLEGAL AND WITHOUT JURISDICTION ALONG WITH THE ATTENDANT ACTIONS; QUASH BY AN ORDER, WRIT OR DIRECTION IN THE NATURE OF CERTIORARI THE NOTICE U/S 148 OF THE ACT DTD. 29.08.2024 FOR AY 2018-19 BEARING DIN AND NOTICE NO. ITBA/AST/S/148_1/2024- 25/1068141643(1) DTD. 29.08.2024 ISSUED BY THE R-1 IN ANNEXURE-F FOR BEING ERRONEOUS, UNLAWFUL, ILLEGAL AND WITHOUT JURISDICTION ALONG WITH THE ATTENDANT ACTIONS; QUASH BY AN ORDER, WRIT OR DIRECTION IN THE NATURE OF CERTIORARI THE NOTICE U/S 142(1) OF THE ACT BEARING DIN AND NOTICE NO. ITBA/AST/F/142(1) /2024- 25/1069795837(1) DTD 19.10.2024 FOR AY 2018-19 IN ANNEXURE-G ALONG WITH ATTENDANT ACTIONS BEING ERRONEOUS, UNLAWFUL, ILLEGAL WITHOUT JURISDICTION. - 3 - HC-KAR NC: 2025:KHC:39698 WP No. 31969 of 2024 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 DIN and notices bearing No.ITBA/AST/F/148A/2024-25/1068139736(1) dated 29.08.2024, ITBA/AST/S/148_1/2024-25/1068141643(1) dated 29.08.2024 and ITBA/AST/F/142(1)/2024- 25/1069795837(1) dated 19.10.2024 issued by the respondents – Revenue under Sections 148A(d), 148 and 142(1) of the Income Tax Act, 1961. 2. Heard Sri Ashok A. Kulakarni, learned counsel for the petitioner and Sri Y.V.Raviraj, 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:39698 WP No. 31969 of 2024 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 DIN and notices bearing No. ITBA/AST/F/148A/2024-25/1068139736(1) dated 29.08.2024, ITBA/AST/S/148_1/2024- 25/1068141643(1) dated 29.08.2024 and ITBA/AST/F/142(1)/2024-25/1069795837(1) dated 19.10.2024 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. (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 - 5 - HC-KAR NC: 2025:KHC:39698 WP No. 31969 of 2024 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 2 Sl No.: 57