- 1 - HC-KAR NC: 2026:KHC:31617 WP No. 10833 of 2022 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF JUNE, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 10833 OF 2022 (T-IT) BETWEEN: ABB ASEA BROWN BOVERI LTD., AFFOLTEMSTRASSE 44, P.O. BOX 8131, CH-8050 ZURICH SWITZERLAND, REPRESENTED HEREIN BY ITS AUTHORIZED SIGNATORY, MR. JAYANTA KUMAR CHATTERJEE. …PETITIONER (BY MS. TANMAYEE RAJKUMAR.,ADVOCATE) AND: 1. THE DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, CIRCLE-1, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, KORAMANGALA, BANGALORE-560 095. Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:31617 WP No. 10833 of 2022 2. THE COMMISSIONER OF INCOME-TAX INTERNATIONAL TAXATION, BMTC BUILDING, 80 FEET ROAD, 6TH BLOCK, 80 FEET ROAD, BANGALORE-560 095. 3. CENTRAL BOARD OF DIRECT TAXES NORTH BLOCK, CENTRAL SECRETARIAT, NEW DELHI, DELHI-110 001, REPRESENTED BY THE SECRETARY, TAX POLICY AND LEGISLATION DIVISION. …RESPONDENTS (BY SRI. SANMATHI E I.,ADVOCATE) THIS W.P. IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO QUASHING THE CERTIFICATE DATED 18.05.2022 ISSUED BY THE R1 UNDER SECTION 197 OF THE ACT (ANNEXURE-D) FOR THE PERIOD 18.05.2022 TO 31.03.2023; QUASHING THE CIRCULAR DATED 03.02.2022 BEARING NO.3/2022 ISSUED BY THE R3 ,ANNEXURE-B; DECLARING THAT ON THE DIVIDENDS TO BE PAID TO THE PETITIONER BY ABB INDIA LTD.TAX AT THE RATE OF 5 PERCENT IS TO BE DEDUCTED IN ACCORDANCE WITH THE DTAA. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: - 3 - HC-KAR NC: 2026:KHC:31617 WP No. 10833 of 2022 CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD ORAL ORDER The learned counsel for the petitioner files a memo seeking leave to withdraw the petition. The memo is placed on record and the petition is dismissed as withdrawn. SD/- (B M SHYAM PRASAD) JUDGE NV