- 1 - HC-KAR NC: 2025:KHC:51188 WP No. 36433 of 2025 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 05TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 36433 OF 2025 (T-IT) BETWEEN: 1. MOTOROLA MOBILITY INDIA PRIVATE LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 HAVING ITS OFFICE AT PLOT NO.5, BAGMANE TECH PARK NO.66/L, 5TH FLOOR, C.V. RAMAN NAGAR BANGALORE – 560 093. REPRESENTED BY ITS AUTHORIZED SIGNATORY MR. PRASHANT HEGDE …PETITIONER (BY SMT. MANASA ANANTHAN FOR SMT. TANMAYEE RAJKUMAR, ADVOCATE) AND: 1. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1(1) - BANGALORE CENTRAL REVENUE BUILDING, QUEENS ROAD BENGALURU – 560 001. Digitally signed by SREEDHARAN BANGALORE SUSHMA LAKSHMI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:51188 WP No. 36433 of 2025 2. THE DIRECTOR GENERAL OF INCOME-TAX (INVESTIGATION) CENTRAL REVENUE BUILDING, QUEENS ROAD BENGALURU – 560 001. …RESPONDENTS (BY SRI. M DILIP, ADVOCATE) --- THIS WRIT PETITION IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA, PRAYING TO-QUASH THE NOTICE DATED 12.08.2025 BEARING NO.ITBA/AST/S/148/2025- 26/1079551383(1) (ANNEXURE-A) ISSUED BY THE 1ST RESPONDENT UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2020-21 AND PASS SUCH OTHER ORDER 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. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR - 3 - HC-KAR NC: 2025:KHC:51188 WP No. 36433 of 2025 ORAL ORDER In this petition, the petitioner seeks the following reliefs: The petitioner, therefore, prays that this Hon’ble Court be pleased to issue a writ, order or direction: a) Quashing the notice dated 12.08.2025 bearing No.ITBA/AST/S/148/2025-26/1079551383(1) (Annexure A) issued by the 1st Respondent under Section 148 of the Act for the assessment year 2020-21; and b) Pass such other order 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 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 - HC-KAR NC: 2025:KHC:51188 WP No. 36433 of 2025 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. (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. - 5 - HC-KAR NC: 2025:KHC:51188 WP No. 36433 of 2025 (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. (ii) The notice dated 12.08.2025 at Annexure-A is hereby quashed. (iii) Liberty is reserved in favour of the respondents to seek revival of this petition, subsequent to disposal of the - 6 - HC-KAR NC: 2025:KHC:51188 WP No. 36433 of 2025 matters pending before the Hon’ble 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 BSS List No.: 2 Sl No.: 21