- 1 - HC-KAR NC: 2025:KHC:40715 WP No. 28154 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 14TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 28154 OF 2025 (T-IT) BETWEEN: M/S KRISHNA E CAMPUS PRIVATE LIMTIED, (A PRIVATE LIMITED COMPANY INCORPORATED UNDE THE COMPANIES ACT 1956) NO. 344, NIRMAL, RMV 2ND STAGE, 1ST CROSS, RMV EXTENSION, BENGALURU - 560 094 KARNATAKA. REPRESENTED BY ITS CHAIRMAN SHRI RAMESH SHYAM BULCHANDANI AGE ABOUT 67 YEARS. …PETITIONER (BY SRI. ASHOK A KULAKARNI, ADVOCATE) AND: THE ASST COMMISSINER OF INCOME TAX, CIRCLE 4(3)(1), BMTC BUILDING, 80 FT ROAD, 6TH BLOCK, KORAMANGALA, BENGALURU KARNATAKA - 560 095 …RESPONDENT (BY SRI. E.I. SANMATHI, ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH BY AN ORDER WRIT OR DIRECTION IN THE NATURE OF CERTIORARI THE ORDER U/S 148A (3) DATED 29.06.2025 FOR AY 2021-22 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A/2025-26/1077986634(1) AT ANNEXURE-D ISSUED BY THE RESPONDENT AS UNLAWFUL AND ILLEGAL ALONG WITH THE ATTENDANT ACTIONS AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:40715 WP No. 28154 of 2025 CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks for the following reliefs: "A. Quash by an order, writ, or direction in the nature of Certiorari the order u/s 148A(3) dated 29.06.2025 for AY 2021-22 bearing DIN & Notice No.ITBA/AST/F/148A/2025-26/1077986634(1) at Annexure "D" issued by the Respondent as unlawful and illegal along with the attendant actions. B. Quash by an order, writ, or direction in the nature of Certiorari the Notice u/s 148 dated 29.06.2025 for AY 2021-22 bearing DIN & Notice No. ITBA/AST/S/148_1/2025-26/1077986798(1) at Annexure "E" issued by the Respondent as unlawful and illegal along with the attendant actions. C. Grant such other relief that this Hon'ble Court may think fit including the cost of this petition in the interest 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 Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of - 3 - HC-KAR NC: 2025:KHC:40715 WP No. 28154 of 2025 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. (ii) Liberty is reserved to the respondents - revenue to revive all these petitions in the event the Apex Court - 4 - HC-KAR NC: 2025:KHC:40715 WP No. 28154 of 2025 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:40715 WP No. 28154 of 2025 (ii) The impugned show cause notices and consequential orders, notices etc., at Annexures-D and E dated 29.06.2025 and 29.06.2025 respectively are hereby quashed. (iii) Liberty is reserved in favour of the respondents - Revenue 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 BMC List No.: 2 Sl No.: 6