- 1 - HC-KAR NC: 2025:KHC:50444 WP No. 36333 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 3RD DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 36333 OF 2025 (T-RES) BETWEEN: 1. MR. PRADEEP KUMAR SHEKAR S/O LATE MR. SHEKAR AGED ABOUT 52 YEARS R/O C501, SALARPURIA SERENITI 5TH MAIN, HSR LAYOUT, SECTOR - 7 BENGALURU - 560 102. (FORMER DIRECTOR M/S PLG POWER AND INFRA PVT. LTD. STRUCK-OFF FROM THE REGISTRAR OF COMPANIES W.E.F., 08.11.2019) 2. MR. SHANKAR SURESH S/O SRI H. SHANKAR SHASTRI AGED ABOUT 51 YEARS R/O NO. 33, 22ND MAIN PADMANABHA NAGAR, BSK II STAGE BENGALURU - 560 070. (FORMER DIRECTOR M/S PLG POWER AND INFRA PVT. LTD. STRUCK-OFF FROM THE REGISTRAR OF COMPANIES W.E.F., 08.11.2019) …PETITIONERS (BY SRI. BHARATH KUMAR .V, ADVOCATE) Digitally signed by CHAITHRA A Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:50444 WP No. 36333 of 2025 AND: 1. UNION OF INDIA REPRESENTED BY ITS PRL. SECRETARY MINISTRY OF FINANCE 3RD FLOOR, JEEVAN DEEP BUILDING SANSAD MARG, NEW DELHI - 110 001. 2. PRL. COMMISSIONER OF INCOME TAX BANGALORE - 3 HAVING OFFICE AT BMTC BUILDING 80 FEET ROAD, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU-560 095. 3. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), BENGALURU HAVING OFFICE AT BMTC BUILDING 80 FEET ROAD, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU-560 095. 4. DEPUTY COMMISSIONER OF INCOME TAX DC/ACIT, CIRCLE-5(1)(1), BLR HAVING OFFICE AT BMTC BUILDING 80 FEET ROAD, NEAR KHB GAMES VILLAGE KORAMANGALA, BENGALURU - 560 095. …RESPONDENTS (BY SRI. M. THIRUMALESH, ADVOCATE) THIS PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO QUASH THE NOTICE DATED 27.01.2023 BEARING DIN AND NOTICE NO. ITBA/AST/F/148A(SCN)/2022-23/1049156303(1) ISSUED BY THE RESPONDENT NO. 3 UNDER SECTION 148A(B) OF THE INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2019-20 IN RESPECT OF M/S PLG POWER AND INFRA PVT. LTD. (ANNEXURE A) AND ETC. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:50444 WP No. 36333 of 2025 CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, the petitioners seek the following reliefs: "a. Issue a writ, order or direction in the nature of certiorari or any other appropriate writ quashing the notice dated 27.01.2023 bearing DIN & Notice No.ITBA/AST/F/148A (SCN)/2022-23/1049156303(1) issued by the Respondent No.3 under Section 148A(b) of the Income Tax Act, 1961 for the assessment year 2019-20 in respect of M/s PLG Power and Infra Pvt. Ltd. (Annexure-A); b. Issue a writ, order or direction in the nature of certiorari or any other appropriate writ quashing the notice dated 13.02.2023 bearing DIN & Notice No.ITBA/AST/F/148A (SCN)/2022-23/1049709143(1) issued by the respondent No.3 under Section 148A(b) of the Income Tax Act, 1961 for the assessment year 2019-20 in respect of M/s PLG Power and Infra Pvt. Ltd. (Annexure-A1); c. Issue a writ, order or direction in the nature of certiorari or any other appropriate writ quashing the notice dated 28.04.2023 bearing DIN & Notice No.ITBA/AST/F/148A (SCN)/2023-24/1052440111(1) issued by the respondent No.3 under Section 148A(b) of the Income Tax Act, 1961 for the assessment year 2019-20 in respect of M/s PLG Power and Infra Pvt. Ltd. (Annexure-A2); d. Issue a writ, order or direction in the nature of certiorari or any other appropriate writ quashing the order dated - 4 - HC-KAR NC: 2025:KHC:50444 WP No. 36333 of 2025 12.05.2023 bearing DIN & Notice No.ITBA/AST/F/148A/ 2023-24/1052802078(1) passed by the Respondent No.3 under Section 148A(d) of the Income Tax Act, 1961 for the assessment year 2019-20 in respect of M/s PLG Power and Infra Pvt. Ltd. (Annexure-B); e. Issue a writ, order or direction in the nature of certiorari or any other appropriate writ quashing the notice dated 12.05.2023 bearing DIN & Notice No.ITBA/AST/S/148_1/ 2023-24/1052802381(1) passed by the Respondent No.3 under Section 148 of the Income Tax Act, 1961 for the assessment year 2019-20 in respect of M/s PLG Power and Infra Pvt. Ltd. (Annexure-C); f. Issue a writ, order or direction in the nature of certiorari or any other appropriate writ quashing the order dated 24.03.2025 bearing DIN and Order No.ITBA/AST/S/147/ 2024-25/1074961725(1) passed by the respondent No.4 under Section 147 R/w Section 144 of the Income Tax Act, 1961 for the assessment year 2019-20 in respect of M/s PLG Power and Infra Pvt. Ltd. (Annexure-D); g. Grant such other relief that this Hon'ble Court may deed fit in the facts of the present matter." 2. Heard learned counsel for the petitioners and learned counsel for the respondents and perused the material on record. - 5 - HC-KAR NC: 2025:KHC:50444 WP No. 36333 of 2025 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 petitioners 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 petitioners 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 - 6 - HC-KAR NC: 2025:KHC:50444 WP No. 36333 of 2025 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 the case - 7 - HC-KAR NC: 2025:KHC:50444 WP No. 36333 of 2025 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 notices and consequential orders, notice etc., at Annexures-A, A1, A2, B, C and D dated 27.01.2023, 13.02.2023, 28.04.2023, 12.05.2023, 12.05.2023 and 24.03.2025 respectively are hereby quashed. (iii) Liberty is reserved in favour of the respondents 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 NBM List No.: 2 Sl No.: 11