K. B. Bhojamma Vs DCIT (Karnataka High Court)
Reassessment Notices u/s 148 & 142(1) Quashed as Being Beyond Scope of s.151A; Karnataka HC Extends Relief to Legal Heir
The Karnataka High Court, in Mrs. K.B. Bhojamma (Legal Heir of Late C. Channappa) vs. DCIT & Ors. (W.P. No. 35585 of 2025, order dated 01-Dec-2025), quashed multiple reassessment notices u/s 148 for AYs 2013-14, 2016-17 & 2017-18, along with consequential notices u/s 142(1), holding that the proceedings were squarely hit by violation of Section 151A of the Income-tax Act, 1961.
The Court followed the binding coordinate bench ruling in Ramachandra Reddy Ravi Kumar vs. DCIT (dated 28-08-2025), wherein it was held that show-cause notices and reassessment proceedings initiated outside the statutory framework of s.151A stand obliterated in law. Applying the same ratio, the High Court ruled that all impugned notices and consequential proceedings against the petitioner, who was proceeded against in her capacity as legal heir, were unsustainable and liable to be quashed.
While granting relief, the Court reserved liberty to the Revenue to seek revival of proceedings depending on the outcome of matters pending before the Supreme Court, and expressly kept all rival contentions open, without expressing any opinion on merits
FULL TEXT OF THE JUDGMENT/ORDER OF KARNATAKA HIGH COURT
