- 1 - HC-KAR NC: 2025:KHC:39271 WP No. 31048 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF SEPTEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE M.NAGAPRASANNA WRIT PETITION NO. 31048 OF 2024 (T-IT) BETWEEN: 1. LENOVO INDIA PRIVATE LIMITED A COMPANY REGISTERED UNDER THE COMPANIES ACT, 1956, HAVING ITS OFFICE AT LEVEL 2 RBD ICON DODDENAKUNDI VILLAGE, MARATHALLI OUTER RING ROAD, MARATHAHALLI POST K R PURAM HOBLI, BANGALORE - 560 037 REPRESENTED BY ITS AUTHORISED SIGNATORY MANAGER - DIRECT - TAX MR. AMITH H RAJA …PETITIONER (BY SMT. 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 NAGAVENI Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:39271 WP No. 31048 of 2024 2. THE DIRECTOR GENERAL OF INCOME-TAX (INVESTIGATION) CENTRAL REVENUE BUILDING, QUEENS ROAD, BENGALURU - 560 001 …RESPONDENTS (BY SRI. M. DILIP, ADVOCATE) THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO DECLARING THAT THE PROCEEDINGS INITIATED UNDER SECTION 148 OF THE ACT FOR THE AY 2017-18 ARE BARRED BY LIMITATION. QUASH THE NOTICE DATED 30.03.2024 BEARING NO. ITBA/AST/S/148-1/2023-24/1063727594(1) (ANNEXURE-A) ISSUED BY THE R-1 UNDER SEC 148 OF THE ACT FOR THE AY 2017-18. THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2025:KHC:39271 WP No. 31048 of 2024 CORAM: HON'BLE MR. JUSTICE M.NAGAPRASANNA ORAL ORDER The petitioner is before this Court, seeking the following prayer: "a) Declaring that the proceedings initiated under Section 148 of the Act for the assessment year 2017-18 are barred by limitation; b) Quashing the notice dated 30.03.2024 bearing no. ITBA/AST/S/148_1/2023-24/1063727594(1) (Annexure A) issued by the 1st Respondent under Section 148 of the Act for the assessment year 2017-18; 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." 2. Heard Smt. Tanmayee Rajkumar, learned counsel for the petitioner and Sri M. Dilip, learned counsel for the respondents. 3. The grounds projected in the subject petition in support of the prayer quoted supra are identical to the ones considered by this Court in W.P.No.28182/2024 and connected matters, disposed on 28.08.2025. - 4 - HC-KAR NC: 2025:KHC:39271 WP No. 31048 of 2024 4. In the light of the issue being similar and the reasons rendered therein becomes applicable to the case at hand, the petition deserves to be disposed on the same lines. Therefore, I pass the following: ORDER (i) The impugned show cause notice 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 this petition would stand quashed. (ii) Liberty is reserved to the respondents - revenue to revive the petition in the event, the Apex Court would hold in favour of the Revenue in the matter pending before it. (iii) With the aforesaid liberty and to the aforesaid extent, the petition is allowed. (iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be - 5 - HC-KAR NC: 2025:KHC:39271 WP No. 31048 of 2024 considered in the event revival of this petition would become necessary. Sd/- (M.NAGAPRASANNA) JUDGE SJK CT-SG List No.: 2 Sl No.: 0