LENOVO GLOBAL TECHNOLOGY (INDIA) PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

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WP/36372/2025HC KarnatakaKAHC01078217202505 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 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 Consequently, the petition was dismissed as withdrawn.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 notice issued under Section 148 of the Income Tax Act, 1961, or the underlying reasons for reassessment. The operative direction was solely to dismiss the petition as withdrawn.

What were the facts?

The petitioner, Lenovo Global Technology (India) Private Limited, filed a writ petition before the High Court of Karnataka. The petition challenged a notice dated 12.08.2025, issued by the Deputy Commissioner of Income Tax, Central Circle 1(1) Bangalore, under Section 148 of the Income Tax Act, 1961, for the Assessment Year 2019-20. The respondents were the Deputy Commissioner of Income Tax and the Director General of Income Tax (Investigation). The petitioner sought to quash the notice. Subsequently, the petitioner's counsel filed a memo seeking to withdraw the petition.

What were the issues?

1. Whether the notice dated 12.08.2025 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's contention, as indicated by the filing of the writ petition, was that the notice was invalid or improperly issued. The revenue's contention, implied by the issuance of the notice, was that there were reasons to believe that income chargeable to tax had escaped assessment for the relevant assessment year. The judgment does not record specific arguments from either side regarding the merits of the notice itself, as the petition was withdrawn.

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. 36372 OF 2025 (T-IT)

BETWEEN:

LENOVO GLOBAL TECHNOLOGY (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 MARATHALLI POST, K RPURAM HOBLI BANGALORE-560037 REPRESENTED BY ITS AUTHORIZED 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 QUASH THE NOTICE DATED 12.08.2025 BEARING NO. ITBA/AST/S/148/2025-26/1079551213(1) (ANNX-A) ISSUED BY THE R1 UNDER SECTION 148 OF THE ACT FIR 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

SA List No.: 4 Sl No.: 0

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