- 1 - HC-KAR NC: 2025:KHC:36697 WP No. 25048 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 15TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 25048 OF 2025 (T-IT) BETWEEN: DELOITTE CONSULTING INDIA DIGITAL SERVICES PRIVATE LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 2013, REPRESENTED BY ITS DIRECTOR, SMT. PRATIMA GOTTUMUKKALA, D/O G V NARASIMHA RAJU, AGED ABOUT 46 YEARS, 163/B, 2ND AND 3RD FLOOR, DOOR NO.10, BANGALORE-560078 ALSO :AT R/O A V FLOOR, H.NO.7.1-621/556 & 557, SAI KRUPA, RESIDING S.R. NAGAR, HYDERBAD, TELANGANA. …PETITIONER (BY SRI. CHANDRASEKHAR V., ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE- 2(2)(1), BANGALORE, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:36697 WP No. 25048 of 2025 KORAMANGALA, BANGALORE-560 095. 2. THE ADDITIONAL COMMISSIONER OF INCOME TAX RANGE - 2(2), BANGALORE, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BANGALORE-560 095. …RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF CONSTITUTION OF INDIA IS PRAYING TO ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE NOTICE DATED 18.03.2025 ISSUED UNDER SECTION 148A(1) OF THE INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2021-22 BY THE RESPONDENT NO.1, BEARING DIN NO.ITBA/AST/F/148A(SCN)-1/2024- 25/1074658890(1) HEREIN ENCLOSED AND MARKED AS ANNEXURE-A AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:36697 WP No. 25048 of 2025 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayer: i) Issue a writ of certiorari or direction in the nature of a writ of certiorari quashing the notice dated 18.03.2025 issued under section 148A(1) of the Income Tax Act, 1961 for the assessment year 2021-22 by the Respondent No.1, bearing DIN No.ITBA/AST/F/148A(SCN)_1/2024- 25/1074658890(1) herein enclosed and marked as Annexure – A1. ii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed under subsection (30 of Section 148A, dated 25.06.2025, passed by the Respondent No.1 for the assessment year 2021-22 bearing DIN No. ITBA/AST/F/148A/2025-26/1077777854(1); herein enclosed and marked as Annexure-A2. iii) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 25.06.2025 issued under section 148 of the Income Tax Act, 1961 for the assessment year 2021-22 by the Respondent No.1, bearing DIN No. ITBA/AST/S/148_1/2025-26/1077795775(1) herein enclosed and marked as Annexure-A3. iv) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” - 4 - HC-KAR NC: 2025:KHC:36697 WP No. 25048 of 2025 2. Heard Sri Chandrasekhar V., 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. 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 - 5 - HC-KAR NC: 2025:KHC:36697 WP No. 25048 of 2025 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.: 115