Infosys Limited Vs DCIT (Karnataka High Court)
Faceless, but Lawless: No Authority, No Reopening- Karnataka HC Strikes Down Reassessment Notice Against Infosys Under Sec.151A
The Petitioner, Infosys Ltd filed a writ petition before the Karnataka High Court challenging the reassessment proceedings initiated by the DCIT, Circle-3(1)(1), Bengaluru, for the AY 2020-21. The impugned proceedings included the order u/s 148A(3) & notice u/s 148, both dated 30.06.2025, which sought to reopen the assessment. The Petitioner contended that the entire process was void ab initio since the notices were issued beyond the jurisdiction prescribed u/s 151A . It was argued that the faceless reassessment procedure introduced under the amended scheme clearly demarcates the powers & authorities competent to issue such notices, & any deviation from that mandate vitiates the proceedings.
The Revenue defended the initiation of reassessment, contending that the notices had been validly issued in accordance with law & that no prejudice was caused to the assessee.
Justice S.R. Krishna Kumar, after hearing both sides, observed that the controversy was squarely covered by the Co-ordinate Bench judgment in Ramachandra Reddy Ravi Kumar v. DCIT (W.P. No.17352/2022 & batch, dated 28.08.2025). In that case, the Court had categorically held that show-cause notices issued by jurisdictional officers outside the scope of Section 151A are without authority of law & that all proceedings arising therefrom stand quashed. Relying on the said precedent, the Court held that the impugned notices & orders in the case of Infosys suffered from the same legal infirmity.
