Bhullar, whose return from injury and a barren two years ended with two wins in the second half of 2016, opened with a six-under 66 that positioned him Tied-third and Shubhankar, whose previous three starts have all yielded finishes inside Tied-11th, was lying Tied-11th with a four-under 68.
Bogey-free Marc Warren, who interestingly also went through a rough stretch in 2015-2016, shot nine-under 63 to open a two-shot lead over 17-year-old Phachara Khongwatmai (65), sole second.
Bhullar (66) had seven birdies against one bogey, while 20-year-old Shubhankar had four birdies, an eagle and two bogeys.
Anirban Lahiri admitted to a wrong call on the club and saw the ball bounce off the cart path and go out of bounds. That cost him a double bogey and he finished at 69 and Tied-19th after being five-under through 16. "It was not a bad swing, it was a wrong club," he said.
More From This Section
Jyoti Randhawa (73), S Chikkarangappa (74), Rahil Gangjee (75) and Mukesh Kumar (77) will need low scores to stay on for the weekend.
Bhullar, who has been spending a lot of time in California after a rough 2014-2015 when he was injured, said, "Things have changed for the better since second half of 2016. A big call in 2015 after being injured in 2014 was I would play events but not put pressure during practice and let it heal. That paid off with good results."
Shubhankar admitted he was enjoying the experience of playing four weeks in a row or with experienced guys. The 20-year-old is soaking in the 'attention' and advice he gets as the youngest member of the 13-strong Indian contingent here in Malaysia.
Shubhankar said, "We're all like a family. It's great to talk with Jeev, Arjun, Jyoti, Shiv, Rahil and others. They are easy to approach and forthcoming. They have good advice to give as they've been playing for a long time.
After retaining his Asian Tour card for 2017, over last three weeks he was T-11th in Singapore, T-9th in Myanmar and T-4 in Bangladesh.
He said, "I'm really pleased. Started with a bogey but brought it back to two under after nine. I hit a lot of good shots on the back nine and made some putts. I'm happy. It's a big event and I really wanted to start well.