LENOVO INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

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WP/36320/2025HC KarnatakaKAHC01078208202509 December 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's counsel seeking to withdraw the writ petition. Consequently, the petition was dismissed as withdrawn. The memo explicitly stated that the petitioner sought to withdraw the petition, leaving all contentions open to be urged before the Assessing Officer in the reassessment proceedings. The Court granted this request, thereby not deciding the merits of the challenge to the Section 148 notice. No specific findings were made on the validity of the notice or the grounds for reassessment. The operative direction was to dismiss the petition as withdrawn.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 12.08.2025, issued by the Deputy Commissioner of Income Tax (R-1) under Section 148 of the Income Tax Act, 1961. This notice was for reassessment proceedings for the Assessment Year 2019-20. The respondents were the Deputy Commissioner of Income Tax and the Director General of Income-Tax (Investigation). The petition 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 12.08.2025 bearing No. ITBA/AST/S/148/2025-26/1079550981(1) issued by the Deputy Commissioner of Income Tax under Section 148 of the Income Tax Act, 1961, for the Assessment Year 2019-20, is liable to be quashed? The petitioner, Lenovo India Private Limited, sought to quash the notice. The judgment does not record specific arguments made by the petitioner or the revenue regarding the validity of the notice or any grounds for quashing it. The petitioner's counsel filed a memo seeking to withdraw the petition.

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. 36320 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 MARATHAHALLI POST, KR 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, QUEENS ROAD, BENGALURU 560 001 2. THE DIRECTOR GENERAL OF INCOME-TAX (INVESTIGATION)

Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA HC-KAR CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU 560 001

…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-DIRECT QUASHING THE NOTICE DATED 12.08.2025 BEARING NO. ITBA/AST/S/148/2025-26/1079550981(1) (ANNX-A) ISSUED BY THE R-1 UNDER SEC 148 OF THE ACT FOR THE AY 2019-20.

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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