Infosys Limited v. Assistant Commissioner of Income Tax, Special Range-3, Bengaluru & Ors.

1. FACTS OF THE CASE

Infosys sought refund of Rs.856,53,19,960, described in its prayer as refunds for AYs 2017-18 and 2018-19 incorrectly adjusted against AY 2016-17 demand, with applicable interest. Its memo dated 25 October 2025 stated the writ had become infructuous and sought withdrawal.

Source: Petition and operative order; PDF 2

2. DISCUSSION BY THE COURT

The Court recorded the withdrawal memo. It did not adjudicate the alleged incorrect adjustment or explain why the dispute had become infructuous.

Source: Petition and operative order; PDF 2

3. JUDICIAL DECISION

The memo was placed on record and the petition disposed of as withdrawn in its terms.

Source: Petition and operative order; PDF 2

4. OUTCOME

The writ ended by withdrawal. No refund or interest payment was directed or confirmed in this order.

Source: Petition and operative order; PDF 2

5. Expert Comments

AKHB editorial analysis, distinct from the Court’s findings.

The refund figure describes the claim

Rs.856,53,19,960 and the three assessment years are stated in the relief sought. They identify the disputed adjustment, but the withdrawal order does not certify either an unlawful set-off or payment of that amount.

Source: PDF p.2

Infructuousness does not explain the intervening event

The petitioner’s memo says the dispute became infructuous without giving the reason. It would be unsafe to infer that Revenue refunded the money, cancelled the demand or agreed to interest. Those events would require the corresponding administrative or payment evidence.

Source: PDF p.2

No refund-adjustment rule was decided

The Court gave effect to a withdrawal request, not a reasoned ruling on the adjustment mechanism. The order is useful for establishing how this writ ended; it cannot support an independent proposition about notice, interest or the legality of setting off refunds.

Source: PDF p.2