- 1 - HC-KAR NC: 2025:KHC:54645 WP No. 38488 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 38488 OF 2025 (T-IT) BETWEEN: M/S RENAISSANCE HOLDINGS AND DEVLEOPERS PRIVATE LIMITED A COMPANY INCORPORATED UNDER THE COMPANIES ACT, HAVING OFFICE AT 50, RENAISSANCE LANDMARK, 17TH CROSS, 8TH MAIN MALLESHWARAM BENGALURU – 560 003 REPRESENTED BY ITS AUTHORISED SIGNATORY SHIR. N S RAMANJ PAN: AAACR6804 …PETITIONER (BY SRI. A. SHANKAR, SENIOR COUNSEL FOR SRI. MADHUSUDHAN U. A., ADVOCATE) AND: 1. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1(4), BLR CENTRAL REVENUE BUILDING, QUEENS ROAD BENGALURU – 560 001 2. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(4), BLR CENTRAL REVENUE BUILDING, QUEENS ROAD BENGALURU – 560 001 3. THE PRINCIPAL COMMISSIONER OF INCOME TAX, C.R. BUILDING, QUEENS ROAD BENGALURU – 560 001 Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:54645 WP No. 38488 of 2025 4. THE COMMISSIONER OF INCOME TAX (APPEALS) - INCOME TAX DEPARTMENT, NFAC, MINISTRY OF FINANCE, ROOM NO 401, 2ND FLOOR, E-RAMP, JAWARLAL NEHRU STADIUM, DELHI – 110 003 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE ASSESSMENT YEAR 2021-22 PASSED UNDER SECTION 147 R.W.S 144 OF THE ACT BY THE RESPONDENT NO.1 BEARING DIN AND ORDER NO. ITBA/AST/S/147/2024-25/1074726911(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 assessment year 2021-22 passed under section 147 r.w.s 144 of the Act by the Respondent No.1 bearing DIN & Order No. ITBA/AST/S/147/2024-25/1074726911(1) herein marked as Annexure - A1. b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Computation Sheet dated 19.03.2025 Issued by the Respondent No.1 bearing DIN & Document No. ITBA/AST/S/621/2024-25/1074726940(1) herein marked as Annexure- A2. - 3 - HC-KAR NC: 2025:KHC:54645 WP No. 38488 of 2025 c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the Notice of demand issued under section 156 of the Act dated 19.03.2025 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/156/2024-25/1074726943(1) herein marked as Annexure - A3. d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice issued under section 148 of the Act dated 29.03.2024 bearing DIN & Notice No. ITBA/AST/S/148_1/2023-24/1063646967(1) issued by the Respondent No.1 herein marked as Annexure - A4. e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the copy of the approval granted under section 151 of the Act by Respondent No.3 for the year 2021-22 bearing DIN No. ITBA/AST/S/118/2023- 24/1063599775(1) herein marked as Annexure - A5. f) Issuing appropriate directions to the Learned Commissioner of Income Tax (Appeals) [CIT(A)] i.e. Respondent No.4 in relation to the appeal pending before it for the assessment year 2021-22. g) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity.” 2. learned counsel for the petitioner and learned counsel for the respondents and perused the material on record. - 4 - HC-KAR NC: 2025:KHC:54645 WP No. 38488 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 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 - 5 - HC-KAR NC: 2025:KHC:54645 WP No. 38488 of 2025 (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 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. - 6 - HC-KAR NC: 2025:KHC:54645 WP No. 38488 of 2025 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, A3, A4 and A5 dated 19.03.2025, 19.03.2025, 19.03.2025, 29.03.2024 and 29.03.2024, respectively, are hereby quashed. iii) The Commissioner of Income Tax (Appeals) is directed to dispose of appeal pertaining to Assessment Years 2021-22 as having rendered academic/infructuous by reserving liberty in favour of both petitioner and respondents to seek revival/restoration if the occasion so arises. iv) 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 Retyped and replaced vide Court order dated 30.01.2026 - 7 - HC-KAR NC: 2025:KHC:54645 WP No. 38488 of 2025 in this regard are kept open and no opinion is expressed on the same. v) It is needless to state that in the event the present petition stands revived as stated supra, after disposal of the petition before the Apex Court, all contentions urged by both the sides are kept open including the contention of the petitioner as regards validity of the search, seizure and inspection proceedings conducted by the respondents. Sd/- (S.R.KRISHNA KUMAR) JUDGE BMC List No.: 4 Sl No.: 32 Inserted vide Court order dated 30.01.2026