- 1 - HC-KAR NC: 2025:KHC:44362 WP No. 32751 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 4TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 32751 OF 2024 (T-IT) BETWEEN: NIKE INDIA PRIVATE LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 HAVING OFFICE AT 66/1, GROUND AND FIRST FLOOR OLYMPIA BUILDING, BAGMANE TECH PARK C V RAMAN NAGAR, BENGALURU-560093 REPRESENTED BY ITS DIRECTOR SUCHITRA BHAT …PETITIONER (BY SMT. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. DEPUTY / ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 5(1)(1), BANGALORE BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU-560095 2. CHIEF COMMISSIONER OF INCOME TAX-1 BMTC BUILDING, 80 FEET ROAD KORAMANGALA, BENGALURU-560095 …RESPONDENTS (BY SRI.M.THIRUMALESH, ADVOCATE FOR R1 & R2) THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO A) QUASH THE ORDER DATED 31/08/2024 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A/2024-25/1068212704(1) (ANN-P) PASSED BY THE Digitally signed by HEMALATHA A Location: HIGH COURTOF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:44362 WP No. 32751 of 2024 R1 UNDER SECTION 148A(d) OF THE ACT FOR THE ASSESSMENT YEAR 2018-19 AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN 'B' GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER 1. In this petition, the petitioner seeks the following reliefs: "a) Quashing the order dated 31/08/2024 bearing DIN and Notice No. ITBA/AST/F/148A/2024- 25/1068212704(1) (Annexure-P) passed by the Respondent No.1 under Section 148A(d) of the Act for the assessment year 2018-19. b) Quashing of the notice dated 31/08/2024 bearing DIN and Notice No. ITBA/AST/S/148-1/2024- 55/106813299(1) (Annexure-Q) passed by the Respondent No.1 under Section 148 of the Act for the assessment year 2018-19. c) Pass such other or further orders as this Hon'ble Court may deem fit in the facts and circumstances of the case, in the interests of justice and equity." 2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. 3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitioner invited my attention to the order of a Co-ordinate Bench of this Court in the case of - 3 - HC-KAR NC: 2025:KHC:44362 WP No. 32751 of 2024 Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order. 4. Per contra, learned counsel for the respondents submits that there is no merit in the petition and that the same is liable to be dismissed. 5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under: "13. I, therefore, pass the following: O R D E R (i) The impugned show cause notices 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 these cases would stand quashed. - 4 - HC-KAR NC: 2025:KHC:44362 WP No. 32751 of 2024 (ii) Liberty is reserved to the respondents - revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of these petitions would become necessary." 6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of co-ordinate Bench of this Court in Ramachandra Reddy's case (supra). 7. In the result, I pass the following: ORDER (i) The petition is allowed and disposed of in terms of the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025. - 5 - HC-KAR NC: 2025:KHC:44362 WP No. 32751 of 2024 (ii) The impugned order dated 31.08.2024 at Annexure-P and impugned notice dated 31.08.2024 at Annexure-Q, are hereby quashed. (iii) Liberty is reserved in favour of the respondents to seek revival of this petition, subsequent to disposal of the matters pending before the Apex Court and all rival contentions between the parties in this regard are kept open and no opinion is expressed on the same. Sd/- (S.R.KRISHNA KUMAR) JUDGE DM List No.: 2 Sl No.: 76