Bunts Pakirappa Narayana Rai Vs ITO (Karnataka High Court)
In the matter of Bunts Pakirappa Narayana Rai vs. ITO, the petitioner approached the Karnataka High Court seeking the quashing of multiple notices and orders issued under the Income Tax Act, 1961, relating to the Assessment Year 2018-19. The reliefs sought included quashing notices under Sections 148A(b), 148A(d), 148, 147 r.w.s. 144, 156, 271AAC(1), and 272A(1)(d) of the Act, as well as the associated assessment orders and demand notices. The petitioner invoked the extraordinary jurisdiction of the Court to seek relief, arguing that the notices and consequential proceedings were not validly issued.
The petitioner’s counsel argued that the present case was squarely covered by a recent judgment of a Co-ordinate Bench of the Karnataka High Court in Ramachandra Reddy Ravi Kumar vs. Deputy Commissioner of Income-tax (W.P. No. 17352/2022 and connected matters, dated 28.08.2025). In that case, the Court had held that show cause notices issued outside the scope of Section 151A of the Act were invalid and all further proceedings arising therefrom were to be quashed. The Court in Ramachandra Reddy also clarified that the Revenue retained the liberty to revive such petitions in the event the Supreme Court ruled in its favour on pending matters.
