- 1 - HC-KAR NC: 2025:KHC:54080 WP No. 8999 of 2022 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 16TH DAY OF DECEMBER, 2025 BEFORE THE HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR WRIT PETITION NO. 8999 OF 2022 (T-IT) BETWEEN: INFOSYS BPM LIMITED (REGISTERED U/S 149(3) OF THE COMPANIES ACT, 1956) 26/3. 26/4 AND 26/6, HOSUR ROAD, ELECTRONIC CITY, BENGALRUU – 560 100 REP. BY ITS AUTHORISED SIGNATORY, MR. P. PRAKASH, …PETITIONER (BY SMT. MAHIMA GOUD, FOR SMT. TANMAYEE RAJKUMAR, ADVOCATES) AND: 1. ASSISTANT/DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1) (1), 6th BLOCK, BMTC BUILDING, 80 FT ROAD, KORAMANGALA, BENGALURU – 560 095 2. PRINCIPAL COMMISSIONER OF INCOME TAX -3 6th BLOCK, BMTC BUILDING 80ft ROAD, KORAMANGALA BENGALURU – 560 095 …RESPONDENTS (BY SRI. E.I. SANMATHI, ADVOCATE) THIS W.P. IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO DECLARE THAT THE IMPUGNED PROCEEDINGS INITIATED BY THE R-1 UNDER SECTION 147 READ WITH SECTION 148 OF THE ACT AS PER Digitally signed by CHANDANA B M Location: High Court of Karnataka - 2 - HC-KAR NC: 2025:KHC:54080 WP No. 8999 of 2022 OPPOSED TO THE SAID PROVISIONS AND THEREFOR WITHOUT JURISDICTION AND ETC., THIS PETITION, COMING ON FOR PRELIMINARY HEARING IN ‘B’ GROUP, 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: (i) Declaring that the impugned proceedings initiated by the 1st Respondent under Section 147 read with Section 148 of the Act are opposed to the said provisions and therefore without jurisdiction; (ii) Quashing the notice dated 31.03.2022 bearing DIN No. ITBA/AST/S/148_1/2021-22/104288155(1) (Annexure G) issued by the 1st Respondent under Section 148 of the Act for the assessment year 2018-19; (iii) Quashing the order dated 31.03.2022 bearing DIN No. ITBA/AST/F/148A/2021-2022/1042385792(1) (Annexure F) passed by the 1st Respondent rejecting the Petitioner's objections to the reassessment proceedings; and (iv) Pass such other or further order 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 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 - 3 - HC-KAR NC: 2025:KHC:54080 WP No. 8999 of 2022 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 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: O R D E R (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. - 4 - HC-KAR NC: 2025:KHC:54080 WP No. 8999 of 2022 (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 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. - 5 - HC-KAR NC: 2025:KHC:54080 WP No. 8999 of 2022 (ii) The impugned show cause notices and consequential orders, notices etc., at Annexures- G and F both dated 31.03.2022 are hereby quashed. (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 MDS List No.: 2 Sl No.: 54