Sankaranarayanan Constructions (P.) Ltd. Vs ACIT (Karnataka High Court)
The petitioner sought multiple reliefs from the Karnataka High Court, primarily requesting quashing of the assessment order dated 27.09.2023 passed under Section 147 of the Income Tax Act for Assessment Year 2018–19, along with the computation sheet, demand notice under Section 156, penalty notice issued under Section 274 read with Section 270A, the notice issued under Section 148 dated 04.07.2022, and the appellate order dated 28.02.2025 under Section 250. The petitioner also sought directions to the Income Tax Appellate Tribunal regarding the pending appeal in ITA No. 1272/Bang/2025.
The petitioner argued that pursuant to the Section 148 notice issued on 04.07.2022, the Assessing Officer completed assessment and determined total income at ₹155,05,33,950. The appeal before the appellate authority was dismissed on 28.02.2025, and a further appeal is pending before the ITAT. Meanwhile, a Coordinate Bench of the High Court, in Ramachandra Reddy Ravi Kumar v. Deputy Commissioner of Income Tax (W.P. No. 17352/2022, decided on 28.08.2025), had quashed similar show-cause notices under Section 148 on the ground that the jurisdiction to issue such notices, after implementation of Section 151A and the related notification, lay exclusively with the faceless authority, not the jurisdictional Assessing Officer. Relying on this decision, the petitioner submitted that the impugned notices and assessment orders in the present case also deserved to be quashed.
