Karnataka High Court
Zoom Car India Private Limited vs The Deputy Commissioner Of Income Tax on 4 November, 2025
Author: S.R.Krishna Kumar
Bench: S.R.Krishna Kumar
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WP No. 15900 of 2024
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 4TH DAY OF NOVEMBER, 2025
BEFORE
THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
WRIT PETITION NO. 15900 OF 2024 (T-IT)
BETWEEN:
ZOOM CAR INDIA PRIVATE LIMITED
COMPANY INCORPORATED UNDER THE COMPANIES
ACT, 1956 AND HAVING ITS OFFICE AT ANJANEYA
TECHNO PARK NO 147,
1 FLOOR HAL OLD AIRPORT ROAD,
ISRO COLONY, KODIHALLI, BANGALORE 560 008
REPRESENTED BY ITS DIRECTOR (FINANCE)
MR. ABHIJIT BANERJEE
S/O LATE P.K. BANERJEE,
AGED ABOUT 52 YEARS
HAVING HIS OFFICE AT ANJANEYA TECHNO PARK
NO 147, 1ST FLOOR HAL OLD AIRPORT ROAD,
ISRO COLONY, KODIHALLI, BANGALORE 560 008
...PETITIONER
(BY SRI.MOHIT RAVAL, ADVOCATE FOR
SRI. MOHAN MAIYA G L, ADVOCATE)
Digitally signed by AND:
HEMALATHA A
Location: HIGH
COURTOF 1. THE DEPUTY COMMISSIONER OF INCOME TAX
KARNATAKA CIRCLE 7(1)(1), BENGALURU
HAVING HIS OFFICE AT BMTC BUILDING,
80 FEET ROAD, 6TH BLOCK,
NEAR KHB GAMES VILLAGE, KORAMANGALA,
BENGALURU 560 095
2. THE COMMISSIONER OF INCOME TAX,
BENGALURU-2
HAVING HIS OFFICE AT BMTC BUILDING,
80 FEET ROAD, 6TH BLOCK,
NEAR KHB GAMES VILLAGE, KORAMANGALA,
BENGALURU 560 095
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3. THE PRINCIPAL COMMISSIONER OF INCOME TAX,
BENGALURU-2
HAVING HIS OFFICE AT BMTC BULIDING,
80 FEET ROAD, 6TH BLOCK,
NEAR KHB GAMES VILLAGE, KORAMANGALA,
BENGALURU 560 095
4. THE ASSESSMENT UNIT/VERIFICATION UNIT/
TECHNICAL UNIT/ REVIEW UNIT,
NATIONAL FACELESS ASSESSMENT CENTRE,
THROUGH THE PRINCIPAL CHIEF COMMISSIONER OF
INCOME TAX (NATIONAL FACELESS ASSESSMENT
CENTRE), DELHI
ROOM NO. 401, 2ND FLOOR, E-RAMP,
JAWAHARLAL NEHRU STADIUM,
NEW DELHI 110003
5. THE UNION OF INDIA,
THROUGH THE SECRETARY,
DEPARTMENT OF FINANCE, MINISTRY OF FINANCE,
NORTH BLOCK, NEW DELHI 110 001
...RESPONDENTS
(BY SRI.E.I.SANMATHI, ADVOCATE FOR R1 TO R4;
SRI.MADANAN PILLAI, ADVOCATE FOR R5)
THIS WP IS FILED UNDER ARTICLE 226 OF THE
CONSTITUTION OF INDIA PRAYING TO A) CALLING FOR THE
RECORDS PERTAINING TO THE PETITIONERS CASE AND AFTER
GOING INTO THE VALIDITY AND LEGALITY THEREOF BE PLEASED
TO QUASH AND SET ASIDE THE IMPUGNED NOTICE DATED
29/03/2024 ISSUED BY THE R1 UNDER SECTION 148 OF THE ACT
(ANNEXURE-A) DIN AND NOTICE NO. ITBA/AST/S/148-1/2023-
24/1063650687(1) AND THE IMPUGNED ORDER DATED 29/03/2024
PASSED BY THE R1 UNDER SECTION 148A(d) OF THE ACT
(ANNEXURE-B) NO. ITBA/AST/S/F/148A/2023-24/1063650590(i) AND
ETC.,
THIS PETITION, COMING ON FOR PRELIMINARY HEARING,
THIS DAY, ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
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ORAL ORDER
In this petition, the petitioner seeks the following reliefs:
"a) This Hon'ble Court be pleased to issue a Writ of
Certiorari or a writ in the nature of Certiorari or any other writ,
order or direction under Article 226 of the Constitution of India
calling for the records pertaining to the petitioners case and
after going into the validity and legality thereof be pleased to
quash and set aside the impugned notice dated 29/03/2024
issued by the Respondent No.1 under section 148 of the Act
(Annexure-A) DIN and notice No. ITBA/AST/S/148-1/2023-
24/1063650687(1) and the impugned order dated 29/03/2024
passed by the Respondent No.1 under section 148A(D) of the
Act (Annexure-B) No. ITBA/AST/S/F/148A/2023-
24/1063650590(1).
b) This Hon'ble Court be pleased to issue a Writ of
Certiorari or a writ in the nature of Certiorari or any other writ,
order or direction under Article 226 of the Constitution of India
prohibiting the Respondents by themselves, their subordinate,
servants and agents from acting upon or taking any further
proceedings in pursuance of and/ or in implementation and/or in
furtherance of the impugned notice DIN and Notice No.
ITBA/AST/S/148-1/2023-24/1063650687(1) dated 29/03/2024
issued by the Respondent No.1 under Section 148 of the Act
(Annexure-A) and the impugned order din and Notice No.
ITBA/AST/F/148A/2023-24/1063650590(1) dated 29/03/2024
passed by the Respondent No.1 under section 148A(D) of the
Act (Annexure-B).
c) This Hon'ble Court be pleased to restrain the
Respondents from giving effect to or initiate any steps or
proceedings in respect of impugned notice DIN and Notice No.
ITBA/AST/S/148/1/2023-24/1063650687(1) dated 29/03/2024
issued by the Respondent No.1 under Section 148 of the Act
(Annexure-A) and the impugned order ITBA/AST/F/148A/2023-
24/1063650590(1) dated 29/03/2024 passed by the
Respondent No.1 under Section 148A(D) of the Act (Annexure-
B) pending the hearing and final disposal of the present petition.
d) Cost of the writ petition may kindly be awarded in favour
of the Petitioner.
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e). The Petitioner be granted any other relief which he is
found entitled to under the law 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. 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
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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:
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
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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 impugned show cause notice dated 29.03.2024 at
Annexure-A and impugned order dated 29.03.2024 at
Annexure-B, 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
DM
