LENOVO INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

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WP/19970/2025HC KarnatakaKAHC01042534202527 October 2025Bench: S.R.KRISHNA KUMAR3 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court of Karnataka accepted a memo filed by the petitioner seeking withdrawal of the writ petition. The memo stated that the petitioner sought leave to withdraw the petition and requested that it be dismissed as withdrawn, leaving all contentions open to be urged before the Assessing Officer in the reassessment proceedings. The Court accepted the memo and ordered the petition to be dismissed as withdrawn. No decision was made on the merits of the case or the validity of the Section 148 notice. The operative direction was the dismissal of the petition as withdrawn.

What were the facts?

The petitioner, Lenovo India Private Limited, filed a writ petition before the High Court of Karnataka challenging a notice dated 29.03.2025, issued by the Deputy Commissioner of Income Tax, Central Circle 1(1) - Bangalore, under Section 148 of the Income Tax Act, 1961. This notice pertained to the assessment year 2018-19. The respondents were the Deputy Commissioner of Income Tax and the Director General of Income Tax (Investigation). The petitioner sought to quash the aforementioned notice. The matter came up for orders before Justice B M Shyam Prasad.

What were the issues?

1. Whether the notice dated 29.03.2025, issued by the Deputy Commissioner of Income Tax under Section 148 of the Income Tax Act, 1961, for the assessment year 2018-19, is liable to be quashed? (Question of law and mixed fact and law) The petitioner's contention, as indicated by the prayer in the writ petition, was that the notice under Section 148 was invalid and ought to be quashed. The specific grounds for challenging the notice were not detailed in the provided text, but the relief sought was its annulment. The respondents' contentions were not recorded in the judgment. The judgment does not mention any specific authorities, circulars, or precedents relied upon by either party in the context of the arguments presented.

Which sections of the Income-tax Act were involved?

Section 148

AI-generated summary — verify with the full judgment below

HC-KAR IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 21ST DAY OF SEPTEMBER, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 19970 OF 2025 (T-IT)

BETWEEN:

LENOVO INDIA PRIVATE LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT 1956 HAVING ITS OFFICE AT LEVEL 2 RBD ICON DODDENAKUNDI VILLAGE, MARATHAHALLI OUTER RING ROAD, MARATHAHALI POST, K R PURAM HOBLI, BENGALURU - 560037 REPRESENTED BY ITS AUTHORISED SIGNATORY MR PRASHANT HEGDE

…PETITIONER (BY MS. TANMAYEE RAJKUMAR.,ADVOCATE) AND:

1.

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1(1) - BANGALORE, CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560001.

Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA HC-KAR

2.

THE DIRECTOR GENERAL OF INCOME - TAX (INVESTIGATION) CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560001.

…RESPONDENTS (BY SRI.Y V RAVIRAJ A/W SRI. M. DILIP., AND SRI. VINAYAKA S PANDIT., ADVOCATES)

THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO A) QUASHING THE NOTICE DATED 29.03.25 BEARING NO. ITBA/AST/S/148/2024-25/1075245510(1) (ANNEXURE A) ISSUED BY THE 1ST RESPONDENT UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2018-19.

THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD

ORAL ORDER

The learned counsel for the petitioner has filed a memo seeking withdrawal of the petition which reads as under.

HC-KAR “The Advocate for the Petitioner seeks leave of this Hon’ble Court to withdraw the above petition.

Wherefore, it is most humbly prayed that this Hon’ble Court may be pleased to take the present memo on record and dismiss the above petition as withdrawn, leaving all contentions open to be urged before the Assessing Officer in the reassessment proceedings, in the interests of justice and equity.”

The memo is accepted and the petition stands dismissed as withdrawn.

Sd/- (B M SHYAM PRASAD) JUDGE

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