Ajit Kanakaraddi Vs DCIT (Karnataka High Court)
Faceless Reopening Reaffirmed: Karnataka HC Again Quashes Section 148 Notices Issued by Jurisdictional AOs
The Karnataka High Court (Dharwad Bench) quashed a batch of reassessment notices issued under section 148 for multiple assessment years, holding that the jurisdictional Assessing Officer lacked authority to initiate reassessment proceedings outside the faceless regime mandated under section 151A of the Income-tax Act, 1961.
The petitioners challenged reassessment notices issued in March 2024 and August 2024 on the ground that, after the CBDT notifications dated 28/29.03.2022, all proceedings relating to income escaping assessment must be undertaken only through automated allocation and in a faceless manner. The notices, however, were admittedly issued by the Central Circle / jurisdictional Assessing Officers.
The Court noted that the issue was no longer res integra and was squarely covered by its earlier detailed judgment in W.P. No. 28182/2024 and connected matters (dated 28.08.2025). Applying the same reasoning, the Court held that notices issued outside the scope of section 151A suffer from lack of jurisdiction and are therefore non est in law.
Accordingly, all impugned notices and consequential proceedings were obliterated and quashed. However, consistent with its earlier approach, the Court reserved liberty to the Revenue to revive the proceedings only if the Supreme Court ultimately upholds the Revenue’s stand in the pending matter. All other contentions of both parties were kept open
FULL TEXT OF THE JUDGMENT/ORDER OF KARNATAKA HIGH COURT
