Navnidhi Infrastructure Private Limited Vs DCIT (Karnataka High Court)
Karnataka HC quashes reassessment notices issued beyond Section 151A mandate — grants liberty to Revenue to revive post-SC verdict
The Petitioner-company, represented by Director, challenged a series of reassessment proceedings for AY 2020-21, including:
- Notice u/s 148A(1) dated 22.03.2025,
- Letter dated 12.06.2025,
- Order u/s 148A(3) dated 27.06.2025, &
- Notice u/s 148 dated 27.06.2025.
The Petitioner contended that the notices were issued beyond the statutory limits prescribed u/s 151A & thus lacked jurisdiction. The Respondents (Revenue) were represented by Sri Tirumalesh M., Advocate. The Petitioner relied upon the Co-ordinate Bench ruling in Ramachandra Reddy Ravi Kumar v. DCIT (WP No.17352/2022 & batch, decided on 28.08.2025), wherein similar notices were quashed on the ground that they were issued outside the permissible scope of Sec. 151A of the Act, which delineates the jurisdictional & procedural authority for issuance of notices under the faceless
reassessment scheme. Justice S.R. Krishna Kumar accepted that the issue was squarely covered by the above precedent & therefore the same reasoning applied to the present case.
Held
- Petition allowed following Ramachandra Reddy Ravi Kumar (supra).
- All impugned notices & orders — Annexure-A1 (22.03.2025), A2 (12.06.2025), A3 & A4 (both 27.06.2025) — quashed as being outside the scope of Sec. 151A.
- Liberty granted to the Revenue to seek revival of proceedings depending on the outcome of pending cases before the Supreme Court on the same issue.
- All rival contentions kept open.
This ruling is part of the growing line of Karnataka HC decisions following Ramachandra Reddy Ravi Kumar, striking down reassessment notices issued by non-jurisdictional authorities under the faceless regime. The Court reiterated that until the Supreme Court clarifies the validity of such faceless reassessment procedures, any notices issued in contravention of Sec. 151A stand void ab initio — while keeping the door open for revival if the apex court later upholds the Department’s position.
