Bangalore International Airport Ltd. Vs DCIT (Karnataka High Court)
Title 1: High Court Quashes Reassessment: Notices Invalid Due to Sec. 151A Breach
Faceless Reassessment Voided: Failure to Follow Statutory Sec. 151A Procedure; Karnataka HC quashes reassessment notice to BIAL – follows Ramachandra Reddy ruling on Sec.151A jurisdiction; Tax Reopening Notices Struck Down: Lack of Jurisdiction Under Faceless Regime
The Petitioner, Bangalore International Airport Ltd. (BIAL), represented by CFO, challenged the reassessment proceedings for AY 2021-22 initiated by the DCIT, Circle-2(1)(1), Bengaluru, u/s 148A & 148. The petition sought quashing of: the order u/s 148A(3) dated 30.06.2025 rejecting objections, &
the notice u/s 148 dated 30.06.2025 reopening the assessment.
The Revenue opposed the plea, contending the action was validly initiated.
Justice S.R. Krishna Kumar noted that the matter was squarely covered by the earlier Coordinate Bench judgment in Ramachandra Reddy Ravi Kumar v. DCIT (WP No.17352/2022 & batch, dated 28.08.2025), which had held that show-cause notices issued beyond the scope of Section 151A (defining the jurisdiction & procedural framework for faceless reassessments) are invalid & unenforceable.
The Court reiterated that all such notices issued outside the statutory framework stand quashed, while liberty remains with the Revenue to revive proceedings depending on the Supreme Court’s eventual ruling on the same legal issue.
