- 1 - HC-KAR NC: 2025:KHC:39459 WP No. 20273 of 2022 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. 20273 OF 2022 (T-IT) BETWEEN: MAHRISHI ALLOYS PVT. LTD., A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 REPRESENTED BY ITS DIRCTOR SRI ANKUSH BHUTRA S/O MAHESH CHAND BHUTRA AGED ABOUT 32 YEARS NO 3, 3RD CROSS MAIN ROAD MYSURU ROAD BENGALURU – 560 026. …PETITIONER (BY SRI ANNAMALAI S., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(1)(1), BENGALURU ROOM NO.230, 2ND FLOOR BMTC DEPOT, 6TH BLOCK KORAMANGALA BENGALURU – 560 095. 2. THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX KARNATAKA AND GOA REGION Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39459 WP No. 20273 of 2022 6TH BLOCK, NER KHB GAMES VILLAGE KORAMANGALA BENGALURU – 560 095. …RESPONDENTS (BY SRI SANMATHI E.I., ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE NOTICE ISSUED UNDER SECTION 148A(b) OF THE ACT DATED 31.05.2022 OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R1 BEARING DIN AND LETTER NO.ITBA/COM/F/17/2022-23/1043262139(1) HEREIN MARKED AS ANNEXURE-A1; QUASHING THE ORDER DATED 29.07.2022 PASSED UNDER SECTION 148A(d) OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R1 BEARING DIN AND ORDER NO.ITBA/COM/F/17/2022-23/1044303333(1) HEREIN MARKED AS ANNEXURE-A2; QUASHING THE NOTICE DATED 29.07.2022 ISSUED UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2015-16 BY THE R1 AND BEARING DIN AND NOTICE NO.ITBA/AST/M/148_1/2022- 23/1044315295(1) HEREIN MARKED AS ANNEXURE-A3. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39459 WP No. 20273 of 2022 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- 23/1043262139(1) dated 31.05.2022, ITBA/AST/M/148_1/2022-23/1044315295(1) dated 29.07.2022 and order No.ITBA/COM/F/17/2022-23/1044303333(1) dated 29.07.2022 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 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 - HC-KAR NC: 2025:KHC:39459 WP No. 20273 of 2022 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/17/2022-23/1043262139(1) dated 31.05.2022 and ITBA/AST/M/148_1/2022- 23/1044315295(1) dated 29.07.2022 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:39459 WP No. 20273 of 2022 (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.: 307