Karnataka High Court
Atria Convergence Technologies ... vs Deputy Commissioner Of Income Tax on 29 October, 2025
Author: S.R.Krishna Kumar
Bench: S.R.Krishna Kumar
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NC: 2025:KHC:43302
WP No. 30639 of 2024
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 29TH DAY OF OCTOBER, 2025
BEFORE
THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
WRIT PETITION NO. 30639 OF 2024 (T-IT)
BETWEEN:
1. ATRIA CONVERGENCE TECHNOLOGIES LIMITED
A COMPANY REGISTERED UNDER THE COMPANIES
ACT, 1956
HAVING OFFICE AT NO.1
2ND AND 3RD FLOOR, INDIAN EXPRESS
BUILDING, QUEENS ROAD
BENGALURU - 560 001
REPRESENTED BY ITS FINANCE CONTROLLER
MR VATS SAWHNEY
...PETITIONER
(BY SRI. TANMAYEE RAJKUMAR, ADVOCATE)
AND:
1. DEPUTY COMMISSIONER OF INCOME TAX
Digitally signed CENTRAL CIRCLE 2(4)
by
SHARADAVANI BANGALORE
B
NO.1 C R BUILDING, QUEENS ROAD
Location: High
Court of BENGALURU-560001
Karnataka
2. DIRECTOR GENERAL OF INCOME TAX
(REGISTRATION)
NO.1 C R BUILDING, QUEENS ROAD
BENGALURU-560001
...RESPONDENTS
(BY SRI.Y.V.RAVIRAJ, ADVOCATE)
THIS W.P. IS FILED UNDER ARTICLES 226 AND 227 OF
THE CONSTITUTION OF INDIA, PRAYING TOA) QUASHING THE
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NC: 2025:KHC:43302
WP No. 30639 of 2024
HC-KAR
ORDER DATED 17.04.2024 BEARING
NO.ITBA/COM/M/17/2024-25/1064151802(1) (ANNEXURE J)
PASSED BY THE 1ST RESPONDENT UNDER SECTION 148A(D)
OF THE ACT FOR THE ASSESSMENT YEAR 2016-17.B.
QUASHING OF THE NOTICE DATED 17.04.2024 BEARING
NO.ITBA/COM/M/17/2024-25/1064152012(1) (ANNEXURE K)
PASSED BY THE 1ST RESPONDENT UNDER SECTION 148 OF
THE ACT FOR THE ASSESSMENT YEAR 2016-17.
THIS PETITION, COMING ON FOR FINAL HEARING, THIS
DAY, ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
ORAL ORDER
In this petition, 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 order dated 17.04.2024 bearing по.
ITBA/COM/M/17/2024-25/1064151802(1) (Annexure J) passed by the 1st Respondent under Section 148A(d) of the Act for the assessment year 2016-17;
b) Quashing of the notice dated 17.04.2024 bearing no. ITBA/COM/M/17/2024-25/1064152012(1) (Annexure K) passed by the 1st Respondent under Section 148 of the Act for the assessment year 2016-17;
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 interests of justice and equity."
2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record.
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NC: 2025:KHC:43302 WP No. 30639 of 2024 HC-KAR
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 - -4-
NC: 2025:KHC:43302 WP No. 30639 of 2024 HC-KAR 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:
ORDER
(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: -5-
NC: 2025:KHC:43302 WP No. 30639 of 2024 HC-KAR 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-J and K dated 17.04.2024 and 17.04.2024 respectively 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 BSV List No.: 1 Sl No.: 86