- 1 - HC-KAR NC: 2025:KHC:47381 WP No. 2530 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 12TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 2530 OF 2024 (T-IT) BETWEEN: QUEST GLOBAL ENGINEERING LIMITED, A COMPANY INCORPORATED UNDER THE COMPANIES ACT 2006, LAWS OF THE UNITED KINGDOM, HAVING ITS OFFICE AT DERWENT HOUSE, RTC BUSINESS PARK, LONDON ROAD, DERBY DE24 8UP, UNITED KINGDOM, REP. HEREIN BY ITS AUTHORIZED SIGNATORY, ASHUTOSH GUPTA, (GENERAL MANAGER, FINANCE TAXATION) …PETITIONER (BY SRI. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX ASMNT CIRCLE2(1), BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE – 560 095 2. THE COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) BMTC BUILDING, 6TH BLOCK, 80 FEET ROAD, KORAMANGALA, BANGALORE – 560 095 …RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:47381 WP No. 2530 of 2024 THIS W.P. IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE ORDER DATED 29/04/2022 BEARING NO. ITBA/COM/F/17/2022-23/1042905684(1) (ANNEXURE-B) PASSED BY THE 1ST RESPONDENT UNDER SECTION 148A(d) OF THE ACT, FOR THE ASSESSMENT YEAR 2018-19 AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR ORAL ORDER In this petition, petitioner seeks for the following reliefs:- “(a) Quashing the order dated 29.04.2022 bearing No. ITBA/COM/F/17/2022-23/1042905684(1) (Annexure- B) passed by the 1st Respondent under section 148A(d) of the Act, for the Assessment year 2018-19; (b) Quashing the notice dated 29.04.2022 bearing ITBA/COM/F/17/2022-23/1042907696(1) (Annexure- C) issued by the 1st Respondent under section 148 of the act for the Assessment Year 2018-19; and (c) Pass such other or further orders as this Hon’ble Court may deem fir in the facts and circumstances of the case, 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 - 3 - HC-KAR NC: 2025:KHC:47381 WP No. 2530 of 2024 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 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 - 4 - HC-KAR NC: 2025:KHC:47381 WP No. 2530 of 2024 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 of Ramachandra Reddy Ravi Kumar Vs. - 5 - HC-KAR NC: 2025:KHC:47381 WP No. 2530 of 2024 Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025. (ii) The impugned order dated 29.04.2022 at Annexure- B and the impugned notice dated 29.04.2022 at Annexure-C passed/issued by respondent No.1 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.: 78