Marlabs Innovations Private Limited vs Deputy Commissioner Of Income Tax
2025 Latest Caselaw 9565 Kant

Karnataka High Court

Marlabs Innovations Private Limited vs Deputy Commissioner Of Income Tax on 29 October, 2025

Author: S.R.Krishna Kumar

Bench: S.R.Krishna Kumar

                                              -1-
                                                        NC: 2025:KHC:43301
                                                      WP No. 30360 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. 30360 OF 2024 (T-IT)
                   BETWEEN:

                   1.  MARLABS INNOVATIONS PRIVATE LIMITED
                       A COMPANY REGISTERED UNDER THE COMPANIES
                       ACT 1956
                       HAVING OFFICE AT PRIMECO UNION CITY,
                       WING-1, BLOCK -B, 7TH FLOOR
                       SADARAMANGALA INDUSTRIAL AREA
                       KRISHNARAJAPURAM
                       BANGALORE - 560 067
                       REPRESENTED BY ITS
  4                    DIRECTOR
                       MR. MANISH SINGHVI
                                                            ...PETITIONER
                   (BY SRI. TANMAYEE RAJKUMAR.,ADVOCATE)

Digitally signed
                   AND:
by
SHARADAVANI
B                  1.    DEPUTY COMMISSIONER OF INCOME TAX
Location: High
Court of                 CIRCLE 4(1)(1)-BANGALORE
Karnataka                BMTC BUILDING, 80 FEET ROAD
                         KORAMANGALA
                         BENGALURU 560 095

                   2.    CHIEF COMMISSIOENR OF INCOME TAX-1
                         BMTC BUILDING
                         80 FEET ROAD, KORAMANGALA
                         BENGALURU 560 095
                                                              ...RESPONDENTS
                   (BY SRI. E.I.SANMATHI, ADVOCATE)
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                                              NC: 2025:KHC:43301
                                          WP No. 30360 of 2024


HC-KAR




     THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF
THE CONSTITUTION OF INDIA, PRAYING TO-QUASH THE
ORDER DTD 31.08.2024 BEARING NO. ITBA/AST/F/148A/2024-
25/1068224325(1) (ANNEXURE-G) PASSED BY THE R-1 UNDER
SEC 148A(d) OF THE ACT FOR THE AY 2018-19QUASH OF THE
NOTICE DTD 31.08.2024 BEARING NO. ITBA/AST/S/148-
1/2024-25/1068226340(1) (ANNEXURE-H) PASSED BY THE R-1
UNDER SEC 148 OF THE ACT FOR THE AY 2018-19 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, 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 31.08.2024 bearing по. G) (Annexure ITBA/AST/F/148A/2024-25/1068224325(1) passed by the 1st Respondent under Section 148A(d) of the Act for the assessment year 2018-19;

b) Quashing of the notice dated 31.08.2024 bearing no. ITBA/AST/S/148_1/2024-25/1068226340(1) (Annexure H) passed by the 1st Respondent under Section 148 of the Act for the assessment year 2018-19;

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.

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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:

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."

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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 notices and consequential orders, notices etc., at Annexures- G and H dated 31.08.2024 and 31.08.2024 are 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

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between the parties in this regard are kept open and no opinion is expressed on the same.

Sd/-

(S.R.KRISHNA KUMAR) JUDGE

BSV