- 1 - HC-KAR NC: 2025:KHC:41530 WP No. 26476 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 16TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 26476 OF 2025 (T-IT) BETWEEN: GOOGLE INDIA PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 HAVING ITS REGISTERED OFFICE AT 4TH AND 5TH FLOOR, RMZ INFINITY, NO. 3, TOWER E, OLD MADRAS ROAD, BENGALURU – 560 016 …PETITIONER (BY SRI. PRERNA PONAPPA, ADVOCATE) AND: DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU – 560 095 …RESPONDENT (BY SRI. M. THIRUMALESH, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE IMPUGNED NOTICE DATED 22.03.2025 ISSUED BY THE RESPONDENT UNDER SECTION 148A(1) OF THE INCOME-TAX ACT, 1961 (ACT) IN THE CASE OF THE PETITIONER FOR ASSESSMENT YEAR (AY) 2019-20, BEARING DOCUMENT IDENTIFICATION NUMBER ITBA/AST/F/148A(SCN)_1/2024-25/1074873277(1) PRODUCED HEREWITH AS ANNEXURE – A AND ETC., THIS PETITION, COMING ON FOR FINAL 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:41530 WP No. 26476 of 2025 CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks for the following reliefs: “I. Quash the impugned notice dated 22.03.2025 issued by the Respondent under section 148A(1) of the Income-Tax Act, 1961 (“Act”) in the case of the Petitioner for Assessment Year (“AY) 2019-20, bearing Document Identification Number ITBA/AST/F/148A(SCN)_1/2024-25/10748732771) produced herewith as ANNEXURE – A; II. Quash the impugned notice dated 25.03.2025 issued by the Respondent under section 148A(1) of the Act in the case of the Petitioner for AY 2019-20, bearing document Identification Number ITBA/AST/F/148A(SCN)_1/2024-25/1075018852 (1) produced herewith as ANNEXURE-B; and III. Quash the impugned order dated 30.06.2025 passed by the Respondent (with prior approval of the Joint Commissioner of Income Tax, Range 3(1), Bangalore) under section 148A(3) of the Act, in the case of Petitioner for AY 2019-20, bearing Document Identification Number ITBA/AST/F/148A/2025- 26/1078035830 (1) produced herewith as ANNEXURE – C; IV. Quash the impugned notice dated 30.06.2025 issued by the Respondent under section 148 of the Act in the - 3 - HC-KAR NC: 2025:KHC:41530 WP No. 26476 of 2025 case of the Petitioner for AY 2019-20, bearing Document Identification Number ITBA/AST/S/148A_1/2025-26/1078036643 (1) produced herein as ANNEXURE-D; and IV. Pass such other orders/directions as this Hon’ble Court may deem appropriate in the facts and circumstances of the case in hand in the interest of justice and equity.” 2. Heard learned counsel for the petitioner and learned counsel for the respondent 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 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 respondent submits that there is no merit in the petition and that the same is liable to be dismissed. - 4 - HC-KAR NC: 2025:KHC:41530 WP No. 26476 of 2025 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 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 - 5 - HC-KAR NC: 2025:KHC:41530 WP No. 26476 of 2025 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. (ii) The impugned show cause notices and consequential orders, notices etc., at Annexures-A, B, C and D dated 22.03.2025, 25.03.2025, 30.06.2025 and 30.06.2025 respectively, are hereby quashed. (iii) Liberty is reserved in favour of the respondent - 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.: 0