- 1 - HC-KAR NC: 2025:KHC:40168 WP No. 29554 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 10TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 29554 OF 2025 (T-IT) BETWEEN: M/S NORTHROOF VENTURES PRIVATE LIMITED REPRESENTED BY ITS AUTHORISED SIGNATORY SHRI. RAMESH KARUR RAGHAVENDERAN AGED ABOUT 58 YEARS, NO.1/8, 1ST FLOOR, 41, CASTLE STREET, OPP. SACRED HEART CHRUCH RICHMOND ROAD, ASHOK NAGAR RICHMOND TOWN, BENGALURU - 560 025. …PETITIONER (BY SRI. MADHUSUDHAN U A, ADVOCATE) AND: 1. THE DEPUTY / ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-5(1) (1), BENGALURU BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 2. THE JOINT COMMISSIONER OF INCOME-TAX 2, BENGALURU, RANGE 3(1) BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, KORAMANGALA, BENGALURU - 560 095. 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX 3, BENGALURU, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, NEAR KHB GAMES VILLAGE, Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:40168 WP No. 29554 of 2025 KORAMANGALA, BENGALURU - 560 095. …RESPONDENTS (BY SRI. M. TIRUMALESH, ADVOCATE) THIS W.P IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUITON OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI OR DIRECTION IN THE NATURE OF A WRIT OF CERTIORARI QUASHING NOTICE DATED 25.03.2025 ISSUED UNDER SECTION 148A(1) OF THE INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2021-22 BY THE RESPONDENT NO.1 BEARING NO.DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)_1/2024- 25/1074987146(1) HEREIN MARKED AS ANNEXURE - A1. 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 petitioner seeks to following reliefs. "a) Issue a writ of Certiorari or direction in the nature of writ of certiorari quashing notice dated: 25.03.2025 issued under section 148A(1) of the Income Tax Act, 1961 for the assessment year 2021-22 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/F/148A(SCN)_1/2024- 25/1074987146(1) herein marked as Annexure-A1. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated: 30.06.2025 passed under Section 148A(3) of the Income Tax Act, 1961 for the assessment year 2021-22 by the - 3 - HC-KAR NC: 2025:KHC:40168 WP No. 29554 of 2025 Respondent No.1 bearing DIN & Notice No.ITBA/AST/F/148A/2025-26/1078036969(1) herein marked as Annexure-A2. c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated: 30.06.2025 issued under section 148 of the Income Tax Act, 1961 for the Assessment year 2021-22 by the Respondent No.1 bearing DIN No.ITBA/AST/S/148-1/2025- 26/1078038017(1) herein marked as Annexure-A3. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing approval under Section 151 of the Act dated: 30.06.2025 of the Income Tax Act, 1961 for the assessment year 2021-22 by the Respondent No.2 bearing DIN & Notice No.ITBA/AST/S/128/2025- 26/1078036671(1) herein marked as Annexure-B. 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 - 4 - HC-KAR NC: 2025:KHC:40168 WP No. 29554 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 - 5 - HC-KAR NC: 2025:KHC:40168 WP No. 29554 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. (ii) The impugned show cause notices and consequential orders, notices etc., at Annexures- A1, A2, A3 and B - 6 - HC-KAR NC: 2025:KHC:40168 WP No. 29554 of 2025 dated 25.03.2025, 30.06.2025, 30.06.2025 and 30.06.2025 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 Srl.