Northroof Ventures Private Limited Vs DCIT (Karnataka High Court)
Faceless Scheme Violation –Reassessment by Jurisdictional AO Outside Section 151A Scope Quashed – Karnataka
Petitioner challenged the reassessment proceedings initiated for AY 2021-22, including the notice u/s 148A(1) dated 25.03.2025, order u/s 148A(3) dated 30.06.2025, approval u/s 151, & notice u/s 148, contending that they were issued by the jurisdictional AO in violation of Section 151A which mandates centralized allocation under the faceless assessment/reassessment scheme.
Relying on the coordinate bench judgment in Ramachandra Reddy Ravi Kumar Vs DCIT (WP No.17352/2022, dated 28.08.2025), the Petitioner argued that such notices issued outside the faceless framework were invalid.
The Court observed that the facts were directly covered by the above precedent, which held that show-cause notices issued by jurisdictional AOs beyond Section 151A were without authority.
Held: Notices & orders issued by the jurisdictional AO outside the scope of Section 151A are invalid & stand quashed. Revenue was given liberty to seek revival if the Supreme Court subsequently rules in its favour on the pending issue.
FULL TEXT OF THE JUDGMENT/ORDER OF KARNATAKA HIGH COURT
In this petition petitioner seeks to following reliefs.
“a) Issue a writ of Certiorari or direction in the nature of writ of certiorari quashing notice dated: 25.03.2025 issued under section 148A(1) of the Income Tax Act, 1961 for the assessment year 2021-22 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/F/148A(SCN)_1/2024-25/1074987146(1) herein marked as Annexure-A1.
b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the order dated: 30.06.2025 passed under Section 148A(3) of the Income Tax Act, 1961 for the assessment year 2021-22 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/F/148A/2025-26/1078036969(1) herein marked as Annexure-A2.
c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated: 30.06.2025 issued under section 148 of the Income Tax Act, 1961 for the Assessment year 2021-22 by the Respondent No.1 bearing DIN No.ITBA/AST/S/148-1/2025-26/1078038017(1) herein marked as Annexure-A3.
d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing approval under Section 151 of the Act dated: 30.06.2025 of the Income Tax Act, 1961 for the assessment year 2021-22 by the Respondent No.2 bearing DIN & Notice No. ITBA/AST/S/128/2025-26/1078036671(1) herein marked as Annexure-B.
e) And pass such other orders as this Hon’ble Court deems fit and proper in the interest of justice and equity.”
2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record.
