- 1 - HC-KAR NC: 2025:KHC:46037 WP No. 17392 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 11TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 17392 OF 2024 (T-IT) BETWEEN: NTT DATA INFORMATION PROCESSING SERVICES PRIVATE LIMITED (FOR THE MERGED ENTITY NTT DATA GLOBAL DELIVERY SERVICES PVT LTD., INTO WHICH, NTT DATA INDIA ENTERPRISES APPLICATION SERVICES PRIVATE LIMITED PREVIOUSLY MERGED) A COMPANY INCORPORATED UNDER THE COMPANIES ACT 1956 HAVING OFFICE AT PLOT NO.178, EPIP PHASE-II, WHITEFIELD INDUSTRIAL AREA, BANGALORE-560 066. REPRESENTED HEREIN BY ITS SENIOR DIRECTOR, MR. SANTHOSH KARAMANGATTIL …PETITIONER (BY SMT. MANASA ANANTHAN, ADVOCATE FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BANGALORE-560 095. 2. THE CHIEF COMMISSIONER OF INCOME TAX BENGALURU-1,CR BUILDING, NO.1 QUEENS ROAD, BENGALURU-560 001. …RESPONDENTS (BY SRI. THIRUMALESH.M, ADVOCATE) THIS W,P IS FILED UNDER ARTICL 226 OF THE CONSTITUTION OF INDIA PRAYING TO DECLARING THAT THE IMPUGNED PROCEEDINGS INITIATED BY THE R1 UNDER SECTION 147 READ WITH SECTION 148 OF Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:46037 WP No. 17392 of 2024 THE ACT ARE OPPOSED TO THE SAID PROVISIONS AND THEREFORE WITHOUT JURISDICTION. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks for the following reliefs:- “ (a) Declaring that the impugned proceedings initiated by the 1st Respondent under Section 147 read with Section 148 of the Act are opposed to the said provisions and therefore without jurisdiction; (b) Quashing of the order dated: 31.03.2024 bearing No.ITBA/AST/F/148A/2023-24/1063785919(1) (Annexure-E) passed by the 1st Respondent under Section 148A(d) of the Act, for the assessment year 2017-18; (c) Quashing the notice dated: 31.03.2024 bearing ITBA/ST/S/148_11/2023-24/1063786160(1) (Annexure-F) issued by the 1st Respondent under Section 148 of the Act for the assessment year 2017-18; (d) Pass such other order further orders as this Hon’ble Court may deem fit in the facts and circumstances of the case, 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 - HC-KAR NC: 2025:KHC:46037 WP No. 17392 of 2024 3. In addition to reiterating the various contentions urged in the 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 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 - 4 - HC-KAR NC: 2025:KHC:46037 WP No. 17392 of 2024 (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 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 - 5 - HC-KAR NC: 2025:KHC:46037 WP No. 17392 of 2024 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- B, C, E and F dated 17.11.2021, 31.01.2024, 31.03.2024 and 31.03.2024 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 Srl.