- 1 - HC-KAR NC: 2025:KHC:37897 WP No. 34243 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 28TH DAY OF AUGUST, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO.34243 OF 2024 (T-IT) BETWEEN: TOYOTA BOSHOKU AUTOMATIVE INDIA PRIVATE LIMITED A PRIVATE COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF INDIA. HAVING ITS REGISTERED OFFICE AT NO.41 BHIMENAHALLI, M N HALLI POST MANCHANAYAKANAHALLI B.O, BIDADI, RAMANAGAR – 562 109, KARNATAKA REPRESENTED BY ITS AUTHORIZED REPRESENTATIVE AND (VICE PRESIDENT- CORPORATE ADMINISTRATION) (YOSHIKATSU YAMAGUCHI) …PETITIONER (BY SRI. ACHAL ANAND V J., ADVOCATE) AND: 1. UNION OF INDIA THROUGH THE SECRETARY, MINISTRY OF FINANCE, GOVERNMENT OF INDIA, Digitally signed by NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:37897 WP No. 34243 of 2024 NORTH BLOCK, NEW DELHI - 110 001 2. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 7(1)(1), BENGALURU BMTC BHAVAN, 80 FEET ROAD, 6TH BLOCK, NEAR NATIONAL GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095 3. CHIEF COMMISSIONER OF INCOME TAX-1, BMTC BHAVAN, 80 FEET ROAD, 6TH BLOCK, NEAR NATIONAL GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095 …RESPONDENTS (BY SRI. TIMMANNA BHAT, ADVOCATE FOR R1; SRI. E. I. SANMATHI, ADVOCATE FOR R2 & R3) THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF THE INDIA PRAYING TO ISSUE A WRIT OF MANDAMUS, OR A WRIT IN THE NATURE OF MANDAMUS, OR ANY OTHER APPROPRIATE WRIT, ORDER OR DIRECTION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA BY QUASHING THE IMPUGNED NOTICE DATED 31.08.2024 AT ANNEXURE–‘B’ DIN NO.ITBA/COM/F/17/2024-25/1068232366) AND THE PROPOSED CONSEQUENTIAL RE-ASSESSMENT PROCEEDINGS WHICH ARE INVALID AND BAD IN LAW. THIS PETITION COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:37897 WP No. 34243 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court seeking the following prayer: “(i) Issue a writ of Mandamus, or a writ in the nature of Mandamus, or any other appropriate writ, order or direction under Article B ITBATC 226 of the Constitution of India, by quashing the Impugned 19/2024-25/Notice and the proposed consequential re-assessment 10682.323667) proceedings which are invalid and bad in law. (ii) Issue a writ of Mandamus or a writ in the nature of Mandamus, or any other appropriate writ, order or direction under Article 226 of the Constitution of India, directing Respondents to merge the Old PAN and New PAN by way of surrender of Old Pan or by any other appropriate manner; (iii) Pass any other order(s) and/ or direction(s) as may be deemed fit, in the interest of justice and equity.” 2. Heard Sri Achal Anand V.J., learned counsel for the petitioner, Sri Thimmanna Bhat, learned counsel for respondent No.1 and Sri E.I.Sanmathi, learned counsel for respondent Nos.2 and 3. 3. The grounds projected in the subject petition in support of the prayer quoted supra are identical to the ones - 4 - HC-KAR NC: 2025:KHC:37897 WP No. 34243 of 2024 considered by this Court in W.P.No.28182/2024 and connected matters, disposed on 28.08.2025. 4. In the light of the issue being similar and the reasons rendered therein becomes applicable to the case at hand, the petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned show cause notice issued by the jurisdictional Assessing Officer outside the scope of Section 151A of the Act stand obliterated. All further proceedings initiated thereto, challenged in this petition would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive the petition in the event, the Apex Court would hold in favour of the Revenue in the matter pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petition is allowed. - 5 - HC-KAR NC: 2025:KHC:37897 WP No. 34243 of 2024 (iv) Contentions of both the parties except the one noted hereinabove shall remain open to be considered and the alternate prayer sought by the petitioner would be considered, in the event revival of this petition becomes necessary. Sd/- (M.NAGAPRASANNA) JUDGE NVJ List No.: 1 Sl No.: 408