Charoen Pokphand Seeds India Private Limited Vs DCIT (Karnataka High Court)
The petitioner challenged multiple proceedings initiated for Assessment Year 2017–18, including a show cause notice under Section 148A(b), an order under Section 148A(d), a reassessment notice under Section 148, the consequent assessment order passed under Section 147 read with Sections 144 and 144B, and the resulting computation sheet and demand notice. The petitioner sought quashing of all these actions through a writ petition.
It was submitted that pursuant to the notice under Section 148A(b), the reassessment proceedings were completed and total income was determined at ₹7,52,26,133. The petitioner had already filed a statutory appeal against the assessment order before the appellate authority, which remained pending. During the pendency of the writ petition, reliance was placed on a judgment of a Coordinate Bench of the Court in Ramachandra Reddy Ravi Kumar, where notices issued under Sections 148A and 148 by a jurisdictional Assessing Officer were quashed on the ground of lack of jurisdiction, in view of Section 151A of the Income-tax Act and the notification introducing the faceless reassessment scheme. It was contended that the same principle applied to the present case and that the impugned notices and consequential proceedings deserved to be set aside.
