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Infosys Limited vs Deputy Commissioner Of Income Tax
2025 Latest Caselaw 9108 Kant

Citation : 2025 Latest Caselaw 9108 Kant
Judgement Date : 13 October, 2025

Karnataka High Court

Infosys Limited vs Deputy Commissioner Of Income Tax on 13 October, 2025

Author: S.R.Krishna Kumar
Bench: S.R.Krishna Kumar
                                              -1-
                                                           NC: 2025:KHC:40498
                                                       WP No. 28391 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. 28391 OF 2025 (T-IT)
                   BETWEEN:

                   INFOSYS LIMITED
                   A COMPANY REGISTERED UNDER
                   THE COMPANIES ACT 1956
                   HAVING OFFICE AT PLOT NO.44
                   KONAPPANA AGRAHARA HOSUR ROAD
                   ELECTRONIC CITY
                   BANGALORE -560100
                   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            BENGALURU -560095.
COURT OF
KARNATAKA           2.    JOINT /ADDITIONAL COMMISSIONER
                          OF INCOME TAX
                          RANGE 3 (1), BANGALORE
                          BMTC BUILDING, 80 FEET ROAD
                          KORAMANGALA
                          BENGALURU- 560095.
                                                               ...RESPONDENTS
                   (BY SRI. M THIRUMALESH, ADV. FOR R1 & R2)

                       THIS PETITION IS FILED UNDER ARTICLE 226 OF THE
                   CONSTITUTION OF INDIA PRAYING TO A) QUASHING THE
                                    -2-
                                                NC: 2025:KHC:40498
                                             WP No. 28391 of 2025


HC-KAR




ORDER DATED 30.06.2025 BEARING NO. ITBA/AST/F/148A/
2025-26/1078057610(1) (ANNEXURE-L) PASSED BY THE 1ST
RESPONDENT UNDER SECTION 148A(3) OF THE ACT FOR THE
ASSESSMENT YEAR 2021-22 AND ETC.

    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/2025-26/1078057610(1) (Annexure-L) 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/ 1078057851(1) (Annexure-N) passed 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 circumstances of the case, in the interests of justice and equity.

NC: 2025:KHC:40498

HC-KAR

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

petitioner 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.

5. As rightly contended by the learned counsel for

the petitioner the present petition is directly and squarely

NC: 2025:KHC:40498

HC-KAR

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.

(iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be

NC: 2025:KHC:40498

HC-KAR

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 notice and

consequential order at Annexure-L and Annexure-N both

dated 30.06.2025 are hereby quashed.

NC: 2025:KHC:40498

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

 
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