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
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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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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.
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(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.
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(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
