- 1 - HC-KAR NC: 2025:KHC:35239 WP No. 19581 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. 19581 OF 2024 (T-IT) BETWEEN: 1. SRI HIREN ATUL RUPARELIA SON OF SRI ATUL A RUPARELIA AGED ABOUT 47 YEARS #142/B, 1ST FLOOR NEAR HOTEL E -INN, 1ST PHASE BOMMASANDRA INDUSTRIAL AREA BANGALORE - 560 099. …PETITIONER (BY SRI. VENKATESH. G, ADVOCATE) AND: 1. 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 Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:35239 WP No. 19581 of 2024 BENGALURU -1 C R BUILDING, QUEENS ROAD BANGALORE - 560 001. 3. THE JOINT COMMISSIONER OF INCOME TAX CIRCLE 1, TPR INCOME TAX OFFICE NO.121, ADAMS BUILDINGS, SIXTY FEET ROAD TIRUPUR - 641 602. …RESPONDENTS (BY SRI M THIRUMALESH, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE NOTICE DTD. 30.04.2024 ISSUED U/S 148 OF THE INCOME TAX ACT, 1961 BEARING DIN AND NOTICE NO. ITBA/AST/S/148-1/2024-25/1064481265(1) BY THE R-1 FOR THE ASSESSMENT YEAR 2017-18 HEREIN MARKED AS ANNX- A2 AND QUASH THE ORDER PASSED UNDER SECTION 148A(d) OF THE INCOME TAX ACT, 1961 DTD. 30.04.2024 BEARING DIN AND NOTICE NO.ITBA/AST/F/148A/2024- 25/1064481227(1) BY THE R-1 FOR THE ASSESSMENT YEAR 2017-18 HEREIN MARKED AS ANNX-A1 AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:35239 WP No. 19581 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner - Assessee is before this Court seeking quashment of notices bearing No.ITBA/AST/S/148_1/2024- 25/1064481265(1) dated 30.04.2024, ITBA/AST/F/148A(SCN)/2023-24/1063597920(1) dated 29.03.2024 and order No.ITBA/AST/F/148A/2024- 25/1064481227(1) dated 30.04.2024 passed by the respondents – Revenue under Sections 148, 148A(b) and 148A(d) of the Income Tax Act, 1961. 2. Heard Sri Venkatesh G., learned counsel for the petitioner and Sri M. Thirumalesh, 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 - 4 - HC-KAR NC: 2025:KHC:35239 WP No. 19581 of 2024 petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned notices bearing No. ITBA/AST/S/148_1/2024-25/1064481265(1) dated 30.04.2024, ITBA/AST/F/148A(SCN)/2023- 24/1063597920(1) dated 29.03.2024 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:35239 WP No. 19581 of 2024 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 387 CT.SM