- 1 - HC-KAR NC: 2025:KHC:39944 WP No. 29341 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 9TH DAY OF OCTOBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 29341 OF 2025 (T-IT) BETWEEN: SAI SRUSTHI INFRASTRUCTURER PRIVATE LIMITED, A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956, REPRESENTED BY ITS DIRECTOR SRI SREENADHA REDDY NAYANI, AGED ABOUT 48 YEARS, SON OF SRI JANARDHAN REDDY NAYANI, PLOT NO. 21, D NO. 8-3-1024, 3RD FLOOR, FLAT NO. 301, JYOTHI HERMITAGE, SRINAGAR COLONY, HYDERABAD - 500 073. ALSO AT. 537, SRIRAM TOWERS, AMARJYOTHI LAYOUT, DOMLUR, NEAR SHELL PETROL BUNK, BENGALURU - 560 071. …PETITIONER (BY SRI. MADHUSUDHAN U. A., ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(2) CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001. 2. THE ADDITIONAL COMMISSIONER OF INCOME TAX, CENTRAL RANGE 2, CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001. …RESPONDENTS (BY SRI. Y. V. RAVIRAJ, ADVOCATE) Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39944 WP No. 29341 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 NOTICE DATED 27.03.2025 ISSUED UNDER SECTION 148A(1) OF THE INCOME TAX ACT, 1961 FOR THE ASSESSMENT YEAR 2019-20 BY THE RESPONDENT NO.1 BEARING DIN NO. ITBA/AST/F/148A(SCN)-1/2024-25/1075152532(1) HEREIN MARKED AS ANNEXURE - A1 AND ETC., 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, the petitioner seeks the following reliefs: "a) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 27.03.2025 issued under section 148A(1) of the Income Tax Act, 1961 for the Assessment Year 2019-20 by the Respondent No.1 bearing DIN No. ITBA/AST/F/148A(SCN)_1/2024- 25/1075152532(1) herein marked as Annexure - A1. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of order dated 29.06.2025 passed under 148A(3) of the Income Tax Act, 1961 for the Assessment Year 2019-20 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/F/148A/2025- 26/1077995673(1) passed by the Respondent No.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 29.06.2025 issued under section 148 of the Income Tax Act, 1961 for the - 3 - HC-KAR NC: 2025:KHC:39944 WP No. 29341 of 2025 Assessment Year 2017-18 by the Respondent No.1 bearing DIN & Order No. ITBA/AST/S/148_1/2025- 26/955555555(1) marked as Annexure- АЗ. d) 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. 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 - 4 - HC-KAR NC: 2025:KHC:39944 WP No. 29341 of 2025 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. (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 - 5 - HC-KAR NC: 2025:KHC:39944 WP No. 29341 of 2025 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 and A3 dated 27.03.2025, 29.06.2025 and 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 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 BMC List No.: 2 Sl No.: 85