PNB MetLife India Insurance Company Limited Vs ACIT (Karnataka High Court)
Karnataka HC quashes reassessment notices issued to PNB MetLife – follows Ramachandra Reddy ruling on Sec.151A jurisdiction
The Petitioner, PNB MetLife India Insurance Company Ltd. filed a writ petition challenging the order u/s 148A(3) and the reassessment notice u/s 148—both dated 29.06.2025—issued by the ACIT, Circle-5(1)(1), Bengaluru for AY 2019-20.
The Petitioner contended that the notices were issued without jurisdiction, as they violated the framework prescribed under Section 151A of the Income-tax Act governing authorization and procedure for faceless reassessment.
The Revenue defended the initiation of proceedings.
Justice S.R. Krishna Kumar noted that the matter was directly covered by the Co-ordinate Bench decision in Ramachandra Reddy Ravi Kumar v. DCIT (WP No.17352/2022 & batch, dated 28.08.2025), wherein the Court had held that show-cause notices issued beyond the scope of Section 151A are void and all subsequent proceedings stand quashed.
Accordingly, the Court held that the impugned notices & consequential orders suffered from the same jurisdictional defect and therefore deserved to be quashed on identical grounds.
Held
- Petition allowed, following Ramachandra Reddy Ravi Kumar (supra).
- Order u/s 148A(3) and notice u/s 148, both dated 29.06.2025, quashed as being beyond the authority of law under Sec.151A.
- Liberty granted to the Revenue to seek revival after the Supreme Court’s decision in pending matters on the same issue.
- All rival contentions kept open, and no opinion expressed on merits.
This ruling extends the series of Karnataka HC judgments (including Navnidhi Infrastructure Pvt. Ltd., Bangalore International Airport Ltd., etc.) applying Ramachandra Reddy Ravi Kumar. It reinforces that any reassessment notice issued by a non-jurisdictional or unauthorized officer under the faceless regime contravenes Section 151A and is void ab initio, pending the Supreme Court’s final verdict on the issue.
