Karnataka High Court
Pnb Metlife India Insurance vs Assistant/Deputy Commissioner Of ... on 13 October, 2025
Author: S.R.Krishna Kumar
Bench: S.R.Krishna Kumar
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NC: 2025:KHC:40497
WP No. 27236 of 2025
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 13TH DAY OF OCTOBER, 2025
BEFORE
THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
WRIT PETITION NO. 27236 OF 2025 (T-IT)
BETWEEN:
PNB METLIFE INDIA INSURANCE
COMPANY LIMITED
A COMPANY REGISTERED UNDER
THE COMPANIES ACT, 1956 AND
HAVING ITS OFFICE AT UNIT NO.701-702-703
RAHEJA TOWERS, WEST WING
BANGALORE-560001
REPRESENTED HEREIN BY ITS
MR. SANJEEV SUMAN
ASSOCIATE DIRECTOR.
...PETITIONER
(BY SRI. TANMAYEE RAJKUMAR, ADV.)
AND:
1. ASSISTANT/DEPUTY COMMISSIONER OF INCOME
TAX
Digitally signed by
NANJUNDACHARI CIRCLE 5(1)(1)
Location: HIGH BMTC BUILDING, 80 FEET ROAD
COURT OF 6TH BLOCK, KORAMANGALA
KARNATAKA
BENGALURU-560 095.
2. JOINT COMMISSIONER OF INCOME TAX
RANGE-3(1), BMTC BUILDING,
80 FEET ROAD, 6TH BLOCK,
KORAMANGALA, BENGALURU-560095.
...RESPONDENTS
(BY SRI.TIRUMALESH M., ADV.)
THIS PETITION IS FILED UNDER ARTICLES 226 AND 227
OF THE CONSTITUTION OF INDIA PRAYING TO A) QUASHING
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WP No. 27236 of 2025
HC-KAR
THE ORDER DATED 29.06.2025 BEARING DIN AND NOTICE NO.
TBA/AST/F/148A/2025-26/1077984254(1) (ANNEXURE -L)
ST
PASSED BY THE 1 RESPONDENT UNDER SECTION 148A(3) OF
THE ACT FOR THE ASSESSMENT YEAR 2019-20 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
ORAL ORDER
In this petition, the petitioner seeks the following
reliefs:
"a) Quashing the order dated 29.06.2025 bearing
DIN and Notice No.TBA/AST/F/148A/2025-
26/1077984254(1) (Annexure-L) passed by the 1st
Respondent under Section 148A(3) of the Act for the
assessment year 2019-20;
b) Quashing of the notice dated 29.06.2025
bearing DIN and Notice No.ITBA/AST/S/148-1/2025-
26/ 1077984268(1) (Annexure-N) passed by the 1st
Respondent under Section 148 of the Act for the
assessment year 2019-20;
(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.
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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
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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:
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
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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 impugned show cause notice and
consequential order at Annexure-L and Annexure-N both
dated 29.06.2025 are hereby quashed.
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(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
MPK
CT:bms
