- 1 - HC-KAR NC: 2025:KHC:49979 WP No. 35967 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 1ST DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 35967 OF 2025 (T-IT) BETWEEN: 1. KARLE HOMES PRIVATE LIMITED COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956, REPRESENTED BY ITS WHOLE TIME DIRECTOR SUDARSHAN KARLE SON OF L T KARLE AGED ABOUT 72 YEARS 151, INDUSTRIAL SUBURB, YESHWANTHPUR, BENGALURU - 560 022. …PETITIONER (BY SRI. ANNAMALAI S., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU, KARNATAKA 560001 2. THE ADDITIONAL COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, CENTRAL RANGE 2, BANGALORE, CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU, KARNATAKA 560001 …RESPONDENTS (BY SRI.M.DILIP, ADVOCATE) Digitally signed by SHARADAVANI B Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:49979 WP No. 35967 of 2025 THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING THE SHOW CAUSE NOTICE ISSUED UNDER SECTION 148A(1) OF THE ACT DATED 27.03.2025 ISSUED BY THE RESPONDENT NO.1 FOR THE ASSESSMENT YEAR 2021-22 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)_1/2024-25/1075152841(1) AND THE SAME IS REFERRED AS ANNEXURE A1 AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, the petitioner seeks the following reliefs: "a. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the show cause notice issued under section 148(1) of the Act dated 27.03.2025 issued by the Respondent No.1 for the assessment year 2021-22 bearing DIN & Notice No.ITBA/AST/F/148A(SCN)_1/2024-25/ 1075152841(1) and the same is referred as Annexure 'A1'. b. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order passed under section 148A(3) of the Act dated 29.06.2025 by the Respondent No.1 for assessment year 2021-22 bearing DIN & Notice No.ITBA/AST/F/148A/2025-26/1077995684(1) and the same is referred as Annexure 'A2'. c. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 148 of the Act - 3 - HC-KAR NC: 2025:KHC:49979 WP No. 35967 of 2025 dated 29.06.2025 by the Respondent No.1 for assessment year 2021-22 bearing DIN & Notice No.ITBA/AST/F/148_1/2025-26/1077995995 (1) and the same is referred as Annexure 'A3'. d. Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the approval issued under section 151 of the Act dated 29.06.2025 by the Respondent No.2 for assessment year 2021-22 bearing DIN & Notice No.ITBA/COMM/17/2025-26/107798543(1) and the same is referred as Annexure 'A4'. e. And pass such other orders as this Hon'ble Court deems fit and proper 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 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 - HC-KAR NC: 2025:KHC:49979 WP No. 35967 of 2025 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 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. - 5 - HC-KAR NC: 2025:KHC:49979 WP No. 35967 of 2025 (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. (ii) The impugned show cause notices and consequential orders, notices etc., at Annexures-A1 dated 27.03.2025 and A2, A3, A4 all dated 29.06.2025 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 - 6 - HC-KAR NC: 2025:KHC:49979 WP No. 35967 of 2025 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 VM List No.: 2 Sl No.: 20