- 1 - HC-KAR NC: 2025:KHC:46506 WP No. 30261 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 10TH DAY OF NOVEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 30261 OF 2025 (T-IT) BETWEEN: EDGEVERVE SYSTEMS LIMITED HAVING OFFICE AT PLOT NO. 44 HOSUR ROAD, ELECTRONIC CITY, PHASE-1, BENGALURU – 560 001 (INCORPORATED U/S COMPANIES ACT, 1956) REPRESENTED BY ITS AUTHORIZED SIGNATORY MR. ANAND KUMAR JAISWAL (SENIOR MANAGER – COROPORATE TAXATION) …PETITIONER (BY SMT. MANASA ANANTHAN, ADVOCATE) AND: 1. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(2)(1) - BANGALORE BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU – 560 095 2. ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE - 2(2), BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU – 560 095 …RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE ORDER DATED 25.06.2025 BEARING DIN ITBA/AST/F/148A/2025- 26/1077758617(1) (ANNEXURE -L) PASSED BY THE 1ST RESPONDENT UNDER SECTION 148A(3) OF THE ACT FOR THE ASSESSMENT YEAR 2021-22 AND ETC., Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:46506 WP No. 30261 of 2025 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 25.06.2025 bearing DIN ITBA/AST/F/148A/2025-26/1077758617(1) (Annexure – ‘L’) passed by the 1st Respondent under Section 148A(3) of the Act for the assessment year 2021-22; b) Quashing the notice dated 25.06.2025 bearing DIN ITBA/AST/S/148_1/2025-26/1077759738(1) (Annexure – ‘M’) issued by the 1st Respondent under Section 148 of the Act for the assessment year 2021- 22; c) Pass such other or further orders as this Hon’ble Court may deem fit 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 record, learned counsel for the petitioner invited my attention to the order of a Co-ordinate Bench of this Court in the case of - 3 - HC-KAR NC: 2025:KHC:46506 WP No. 30261 of 2025 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 proceedings initiated thereto, challenged in these cases would stand quashed. - 4 - HC-KAR NC: 2025:KHC:46506 WP No. 30261 of 2025 (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. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025. - 5 - HC-KAR NC: 2025:KHC:46506 WP No. 30261 of 2025 (ii) The impugned order dated 25.06.2025 and the impugned notice dated 25.06.2025 at Annexures-L and M, respectively, 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.: 99