- 1 - HC-KAR NC: 2025:KHC:42113 WP No. 30982 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 23RD DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 30982 OF 2025 (T-RES) BETWEEN: 1. M/S BROADVISION SERVICES PVT LTD REGISTERD UNDER COMPANIES ACT 1956 (NO.1 OF 1956) NO.4, VASIHNAVI WOODS J.P. NAGARA BY ITS MANAGING DIRECTOR SRI RAMACHANDRASEKARAN …PETITIONER (BY SRI. AMIT ANAND DESHPANDE, ADVOCATE) AND: 1. STATE OF KARNATAKA REPRESENTED BY ITS FINANCE SECRETARY BENGALURU - 560 001 2. THE ASSISTANT COMMISSIONER OF COMMERCIAL TAXES (AUDIT)-3.2, DGSTO-2, 2ND FLOOR TTMC B BLOCK BMTC BUILDING SHANTHINAGARA BENGALURU - 560 027 …RESPONDENTS (BY SRI. JYOTI M. MARADI, HCGP FOR R1 AND R2) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI BY QUASHING THE IMPUGNED SHOW CAUSE NOTICE DTD.06.06.2025 IN NO. ADJU-131/ACCCT(A)- 3.2/2025-26 ISSUED BY THE 2ND RESPONDENT VIDE ANNEXURE-A AND ETC. Digitally signed by SHARADAVANI B Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:42113 WP No. 30982 of 2025 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 the following reliefs: "WHEREFORE, this Hon'ble Court may be pleased to allow this Writ Petition 1. by issuing a writ of certiorari by quashing the impugned show cause notice dated 06.06.2025 in No.ADJU-131/ACCCT(A)- 3.2/2025-26 issued by the 2nd Respondent vide Annexure-A. 2. Grant such other reliefs as deemed fit by this Hon'ble Court in the facts and circumstances of the case, in the interest of justice and equity." 2. Heard the learned counsel for the petitioner and the learned HCGP for the respondents and perused the material on record. 3. Learned counsel for the petitioner submits that while the impugned show cause notice dated 06.06.2025 pertains to the tax period April 2021 to March,2022, in relation to the very same petitioner - assessee, the respondent issued a pre-intimation dated 15.12.2023 to - 3 - HC-KAR NC: 2025:KHC:42113 WP No. 30982 of 2025 which the petitioner submitted reply dated 21.12.2023 and 01.02.2024 pursuant to which the respondents dropped the proceedings vide order dated 30.09.2024 in relation to the tax period 2020-2021. It is submitted that despite dropping the proceedings qua the petitioner in relation to tax period 2020-2021 vide Annexure-H dated 30.09.2024, the respondents have now issued the impugned show cause notice dated 06.06.2025 for the subsequent tax period i.e., April 2021 to March, 2022 and by virtue of doctrine of parity, the impugned show cause notice at Annexure-A dated 06.06.2025 deserves to be quashed. 3. In reply, learned HCGP for the respondents submits that if the petitioner submits his reply to Annexure-A dated 06.06.2025 along with relevant documents, the respondents shall consider the same and proceed further in accordance with law. 4. In view of the aforesaid facts and circumstances, petition stands disposed of reserving - 4 - HC-KAR NC: 2025:KHC:42113 WP No. 30982 of 2025 liberty in favour of the petitioner to submit reply, documents, etc, to Annexure - A dated 06.06.2025 within a period of one month from today. If the petitioner submits that reply, documents etc., the respondents shall consider and proceed further in accordance with law bearing in mind the earlier proceedings in relation to the tax period/assessment year 2020-2021 vide Annexure-H and in accordance with law. Subject to the aforesaid directions, petition stands disposed of. Sd/- (S.R.KRISHNA KUMAR) JUDGE BSV CT-SG List No.: 2 Sl No.: 17