- 1 - HC-KAR NC: 2025:KHC:36583 WP No. 10890 of 2024 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. 10890 OF 2024 (T-IT) BETWEEN: M/S. INTERNATIONAL AEROSPACE MANUFACTURING PRIVATE LIMITED, COMPANY INCORPORATED UNDER COMPANIES ACT, 1956, REPRESENTED BY ITS AUTHORIZED SIGNATORY, SRI. SATHISH SIVARAMAN, SON OF SRI. SIVARAMAN, AGED ABOUT 50 YEARS, SURVEY NO. 3, VARTHUR HOBLI, BANGALORE EAST TALUK, BENGALURU RURAL, KARNATAKA-560 037. …PETITIONER (BY SRI. ANNAMALAI S., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU-560 095. 2. THE CHIEF COMMISSIONER OF INCOME TAX-1, Digitally signed by NAGAVENI Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:36583 WP No. 10890 of 2024 BENGALURU, CENTRAL REVENUE BUILDING, QUEEN’S ROAD, BENGALURU-560 001. …RESPONDENTS (BY SRI. M.THIRUMALESH, ADVOCATE) THIS WP IS FILED UNDER ARTICLE 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE DTD 15.03.2023 ISSUED UNDER SECTION 148A(b) OF THE ACT FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.1 VIDE DIN AND LETTER NO. ITBA/AST/F/148A(SCN)/2022-23/1050802616(1) HEREIN MARKED AS ANNEXURE-A1; ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE DATED 04.10.2023 ISSUED UNDER SECTION 148A(b) OF THE ACT FOR THE ASSESSMENT YEAR 2019-2020 BY THE RESPONDENT NO. 1 VIDE DIN & LETTER NO.ITBA/COM/F/17/2023- 24/1056774601(1) HEREIN MARKED AS ANNEXURE-A2 AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:36583 WP No. 10890 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayers: ‘i. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 15.03.2023 issued under section 148A(b) of the Act for the Assessment Year 2019-2020 by the Respondent No.1 vide DIN & Letter No. ITBA/AST/F/148A(SCN)/2022-23/1050802616(1) herein marked as Annexure-A1. ii. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 04.10.2023 issued under section 148A(b) of the Act for the Assessment Year 2019-2020 by the Respondent No.1 vide DIN & Letter No. ITBA/COM/F/17/2023-24/1056774601(1) herein marked as Annexure-A2. iii. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated 01.02.2024 passed under section 148A(d) of the Act for the Assessment Year 2019-2020 by the Respondent No.1 vide DIN & Notice No. ITBA/AST/F/148A/2023-24/1060366705(1) herein marked as Annexure-A3. iv. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 01.02.2024 issued under section 148 of the Act for the Assessment Year 2019-2020 by the Respondent No.1 vide DIN & Letter No. ITBA/AST/S/148_1/2023-24/1060367404(1) herein marked as Annexure-A4. - 4 - HC-KAR NC: 2025:KHC:36583 WP No. 10890 of 2024 V. And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. Heard Sri. Annamalai S., learned counsel for the petitioner and Sri M.Thirumalesh, learned counsels for the respondents. 3. The grounds projected in the subject petition in support of the prayers 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 show cause notice issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All - 5 - HC-KAR NC: 2025:KHC:36583 WP No. 10890 of 2024 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 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 368