LENOVO INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

PDF · subscribers
WP/19973/2025HC KarnatakaKAHC01042535202527 October 2025Bench: S.R.KRISHNA KUMAR3 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court of Karnataka accepted the memo filed by the petitioner seeking withdrawal of the writ petition. Consequently, the petition was dismissed as withdrawn. The court explicitly stated that all contentions were left open to be urged before the Assessing Officer in the reassessment proceedings, in the interests of justice and equity. No decision was made on the merits of the case concerning the validity of the Section 148 notice. The operative direction was to dismiss the petition as withdrawn.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 March 29, 2025, issued by the Deputy Commissioner of Income Tax under Section 148 of the Income Tax Act, 1961. This notice pertained to the assessment year 2021-22. The respondents in the petition were the Deputy Commissioner of Income Tax and the Principal Commissioner of Income Tax (Central). The petitioner sought to quash the aforementioned notice.

What were the issues?

1. Whether the notice dated 29.03.2025 bearing No. ITBA/AST/S/148/2024-25/1075245575(1) issued by the Deputy Commissioner of Income Tax under Section 148 of the Income Tax Act, 1961, for the assessment year 2021-22 is liable to be quashed? The petitioner's contention, as indicated by the memo filed seeking withdrawal, was that they wished to withdraw the petition. The memo explicitly stated that the petitioner sought leave to withdraw the petition and prayed for it to be dismissed as withdrawn, leaving all contentions open to be urged before the Assessing Officer in the reassessment proceedings. The revenue's contentions are not recorded in the judgment.

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. 19973 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, DODDEKAKUNDI VILLAGE, MARATHAHALLI OUTER RING ROAD, MARATHAHALLI POST, K R PURAM HOBLI, BANGALORE-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,

Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA HC-KAR QUEENS ROAD, BENGALURU-560001.

2.

THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) 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 QUASHING THE NOTICE DATED 29.03.2025 BEARING NO. ITBA/AST/S/148/2024-25/1075245575(1)(ANNEXURE A) ISSUED BY THE 1ST RESPONDENT UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 2021-22

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

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

“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

More judgments on Section 148

All 35,022 judgments and leading authorities on Section 148 →

Recent GST High Court judgments

Search GST case law →