Karnataka High Court
Infosys Bpm Limited vs Deputy Commissioner Of Income Tax on 13 October, 2025
Author: S.R.Krishna Kumar
Bench: S.R.Krishna Kumar
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NC: 2025:KHC:40500
WP No. 28937 of 2025
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 13TH DAY OF OCTOBER, 2025
BEFORE
THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
WRIT PETITION NO. 28937 OF 2025 (T-IT)
BETWEEN:
INFOSYS BPM LIMITED
A COMPANY REGISTERED UNDER
THE COMPANIES ACT, 1956
HAVING OFFICE AT PLOT NO.26/3 26/4 26/6
HOSUR ROAD, ELECTRONIC CITY,
KONAPPANA AGRAHARA,
BANGALORE- 560 100.
REP. BY ITS AUTHORIZED SIGNATORY
MR. ANAND KUMAR JAISWAL.
...PETITIONER
(BY SMT. TANMAYEE RAJKUMAR, ADV.)
AND:
1. DEPUTY COMMISSIONER OF INCOME TAX
CIRCLE 3(1)(1) - BANGALORE
Digitally signed by BMTC BUILDING,
NANJUNDACHARI
80 FEET ROAD, KORAMANGALA,
Location: HIGH
COURT OF BENGALURU-560 095.
KARNATAKA
2. JOINT/ADDITIONAL COMMISSIONER
OF INCOME TAX
RANGE 3(1), BANGALORE,
BMTC BUILDING,
80 FEET ROAD, KORAMANGALA,
BENGALURU- 560 095.
...RESPONDENTS
(BY SRI. M THIRUMALESH, ADV. FOR R1 & R2)
THIS PETITION IS FILED UNDER ARTICLE 226 OF THE
CONSTITUTION OF INDIA PRAYING TO QUASHING THE ORDER
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NC: 2025:KHC:40500
WP No. 28937 of 2025
HC-KAR
DATED 30.06.2025 BEARING NO. ITBA/AST/F/148A/2025-
26/1078046615(1) (ANNEXURE-H PASSED BY THE 1ST
RESPONDENT UNDER SECTION 148A(3) OF THE ACT FOR THE
ASSESSMENT YEAR 2020-21 AND B) QUASHING OF THE
NOTICE DATED 30.06.2025 BEARING NO. ITBA/AST/S/148
1/2025-26/1078051694(1) (ANNEXURE K) PASSED BY THE 1ST
RESPONDENT UNDER SECTION 148 OF THE ACT FOR THE
ASSESSMENT YEAR 2020-21.
THIS PETITION, COMING ON FOR PRELIMINARY
HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR
ORAL ORDER
In this petition, the petitioner seeks the following reliefs:
"a) Quashing the order dated 30.06.2025 bearing No.ITBA/AST/F/148A/2025-26/1078046615(1) (Annexure-H) passed by the 1st Respondent under Section 148A(3) of the Act for the assessment year 2020-21;
b) Quashing of the notice dated 30.06.2025 bearing No.ITBA/AST/S/148-1/2025-26/ 1078051694(1) (Annexure-K) issued by the 1st Respondent under Section 148 of the Act for the assessment year 2020-21;
(c) Pass such other or further orders as this Hon'ble Court may deem fit in the facts and -3- NC: 2025:KHC:40500 WP No. 28937 of 2025 HC-KAR circumstances of the case, in the interests of justice and equity.
2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record.
3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitionnber invited my attention to the order of a Co- ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order.
4. Per contra, learned counsel for the respondents submits that there is no merit in the petition and that the same is liable to be dismissed.
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NC: 2025:KHC:40500 WP No. 28937 of 2025 HC-KAR
5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, the operative portion of which reads as under:
"13. I, therefore, pass the following:
ORDER
(i) The impugned show cause notices 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 these cases would stand quashed.
(ii) Liberty is reserved to the respondents -
revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it.
(iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed. -5-
NC: 2025:KHC:40500 WP No. 28937 of 2025 HC-KAR
(iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of these petitions would become necessary."
6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of co-ordinate Bench of this Court in Ramachandra Reddy's case (supra).
7. In the result, I pass the following:
ORDER
(i) The petition is allowed and disposed of in terms of the decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025.
(ii) The impugned show cause notices and consequential orders, notices etc., at Annexures-H and K both dated 30.06.2025 respectively are hereby quashed. -6-
NC: 2025:KHC:40500 WP No. 28937 of 2025 HC-KAR
(iii)Liberty is reserved in favour of the respondents - Revenue to seek revival of this petition, subsequent to disposal of the matters pending before the Apex Court and all rival contentions between the parties in this regard are kept open and no opinion is expressed on the same.
Sd/-
(S.R.KRISHNA KUMAR) JUDGE MPK CT:bms List No.: 2 Sl No.: 45