MOTOROLA MOBILITY INDIA PRIVATE LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

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WP/36678/2025HC KarnatakaKAHC01078406202505 December 2025Bench: S.R.KRISHNA KUMAR3 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court accepted the memo filed by the petitioner seeking withdrawal of the writ petition. Consequently, the petition was dismissed as withdrawn. The court explicitly noted that all contentions of the petitioner were left open to be urged before the Assessing Officer in the reassessment proceedings. No decision was made on the merits of the case regarding the validity of the Section 148 notice.

What were the facts?

The petitioner, Motorola Mobility 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 (1st Respondent) under Section 148 of the Income Tax Act, 1961. This notice pertained to the Assessment Year 2019-20. The petitioner sought to quash this notice. The second respondent was the Director General of Income-Tax (Investigation). The matter came up for orders before the High Court.

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, through its counsel, sought to withdraw the writ petition. The memo filed by the petitioner stated that they sought leave to withdraw the petition and requested that it be dismissed as withdrawn, leaving all contentions open to be urged before the Assessing Officer in the reassessment proceedings. The revenue's contentions were not recorded as the petition was withdrawn.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. 36678 OF 2025 (T-IT)

BETWEEN:

MOTOROLA MOBILITY INDIA PRIVATE LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956 HAVING ITS OFFICE AT PLOT NO. 5, BAGMANE TECH PARK NO. 66/L, 5TH FLOOR C.V.RAMAN NAGAR, BANGALORE -560093. REPRESENTED BY ITS AUTHORISED SIGNATORYMR. PRASHANT HEGDE.

…PETITIONER (BY MSI. 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 VANAMALA N Location: HIGH COURT OF KARNATAKA HC-KAR

2.

THE DIRECTOR GENERAL OF INCOME-TAX (INVESTIGATION) 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 A) QUASHING THE NOTICE DATED 12.08.2025 BEARING NO. ITBA/AST/S/148/2025-26/1079551598(1) (ANNEXURE A) ISSUED BY THE 1ST RESPONDENT UNDER SECTION 148 OF THE ACT FOR THE ASSESSMENT YEAR 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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