LENOVO INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

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WP/31048/2024HC KarnatakaKAHC01065442202424 September 2025Bench: M.NAGAPRASANNA5 pages
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What did the High Court hold?

The High Court of Karnataka, in its oral order, observed that the grounds projected in the present writ petition were identical to those considered in a previous writ petition (W.P.No.28182/2024) which was disposed of on 28.08.2025. Consequently, the court held that the reasons rendered in the previous order were applicable to the present case. The impugned show cause notice issued by the jurisdictional Assessing Officer outside the scope of Section 151-A of the Act was obliterated, and all further proceedings initiated pursuant to it, as challenged in the petition, were quashed. Liberty was reserved to the revenue to revive the petition if the Apex Court ruled in their favour in a pending matter. The petition was allowed to the extent of quashing the notice and proceedings, with contentions of both parties, except as noted, remaining open for consideration in the event of revival.

What were the facts?

The petitioner, Lenovo India Private Limited, filed a writ petition before the High Court of Karnataka challenging a notice dated 30.03.2024 issued by the Deputy Commissioner of Income Tax (R-1) under Section 148 of the Income Tax Act, 1961, for Assessment Year (AY) 2017-18. The petitioner sought a declaration that the proceedings initiated under Section 148 were barred by limitation and prayed for the quashing of the said notice. The respondents were the Deputy Commissioner of Income Tax and the Director General of Income-Tax (Investigation). The High Court noted that the grounds raised in the present petition were identical to those considered in a previous writ petition (W.P.No.28182/2024) disposed of on 28.08.2025.

What were the issues?

1. Whether the proceedings initiated under Section 148 of the Income Tax Act, 1961, for AY 2017-18 are barred by limitation? 2. Whether the notice dated 30.03.2024 issued by the Deputy Commissioner of Income Tax under Section 148 of the Act for AY 2017-18 is liable to be quashed? The petitioner argued that the proceedings initiated under Section 148 were barred by limitation. The revenue's contentions are not explicitly recorded in the judgment, other than their representation by counsel. The court noted that the grounds projected in the petition were identical to those considered in a prior writ petition disposed of on 28.08.2025.

Which sections of the Income-tax Act were involved?

Section 148,Section 151-A

AI-generated summary — verify with the full judgment below

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HC-KAR NC: 2025:KHC:39271 WP No. 31048 of 2024

IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 31048 OF 2024 (T-IT) BETWEEN:

1.

LENOVO INDIA PRIVATE LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956, HAVING ITS OFFICE AT LEVEL 2 RBD ICON DODDENAKUNDI VILLAGE, MARATHALLI OUTER RING ROAD, MARATHAHALLI POST K R PURAM HOBLI, BANGALORE - 560 037

REPRESENTED BY ITS AUTHORISED SIGNATORY MANAGER - DIRECT - TAX MR. AMITH H RAJA …PETITIONER (BY SMT. TANMAYEE RAJKUMAR, ADVOCATE) AND:

1.

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1(1) - BANGALORE CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001

Digitally signed by NAGAVENI Location: High Court of Karnataka

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HC-KAR NC: 2025:KHC:39271 WP No. 31048 of 2024

2.

THE DIRECTOR GENERAL OF INCOME-TAX (INVESTIGATION) CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE)

THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO DECLARING THAT THE PROCEEDINGS INITIATED UNDER SECTION 148 OF THE ACT FOR THE AY 2017-18 ARE BARRED BY LIMITATION. QUASH THE NOTICE DATED 30.03.2024 BEARING NO. ITBA/AST/S/148-1/2023-24/1063727594(1) (ANNEXURE-A) ISSUED BY THE R-1 UNDER SEC 148 OF THE ACT FOR THE AY 2017-18.

THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

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HC-KAR NC: 2025:KHC:39271 WP No. 31048 of 2024

CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA

ORAL ORDER

The petitioner is before this Court, seeking the following prayer:

"a) Declaring that the proceedings initiated under Section 148 of the Act for the assessment year 2017-18 are barred by limitation; b) Quashing the notice dated 30.03.2024 bearing no. ITBA/AST/S/148_1/2023-24/1063727594(1) (Annexure A) issued by the 1st Respondent under Section 148 of the Act for the assessment year 2017-18; 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."

2.

Heard Smt. Tanmayee Rajkumar, learned counsel for the petitioner and Sri M. Dilip, learned counsel for the respondents.

3.

The grounds projected in the subject petition in support of the prayer quoted supra are identical to the ones considered by this Court in W.P.No.28182/2024 and connected matters, disposed on 28.08.2025.

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HC-KAR NC: 2025:KHC:39271 WP No. 31048 of 2024

4.

In the light of the issue being similar and the reasons rendered therein becomes applicable to the case at hand, the petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned show cause notice 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 this petition would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive the petition in the event, the Apex Court would hold in favour of the Revenue in the matter pending before it.

(iii) With the aforesaid liberty and to the aforesaid extent, the petition is allowed.

(iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be

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HC-KAR NC: 2025:KHC:39271 WP No. 31048 of 2024

considered in the event revival of this petition would become necessary.

Sd/- (M.NAGAPRASANNA) JUDGE

SJK CT-SG List No.: 2 Sl No.: 0

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