Prakash Varadaraj Vs ITO (Karnataka High Court)
Faceless, baseless & now case-less — HC deletes reassessment chain with one click- Karnataka HC quashes faceless reassessment notices issued outside Section 151A procedure
Petitioner, Prakash Varadaraj, represented by Sachin S Nayak., Advocate, challenged multiple digital notices, approvals & orders issued under the faceless assessment regime, relating to A.Y. 2016-17, including notices u/s 148A(b), 148, orders u/s 148A(d), reassessment order u/s 147 r.w.s. 144, penalty orders u/s 271F & 271(1)(c) & consequential demand notices u/s 156, all issued between 03.02.2023 & 30.07.2024
The challenge was on the ground that the entire proceedings were initiated & approved outside the scope of Section 151A, which governs the Faceless Assessment Scheme under the Income-tax Act.
Counsel for Petitioner, Sachin S Nayak., Advocate relied on the recent coordinate Bench ruling in Ramachandra Reddy Ravi Kumar v. DCIT (W.P. No. 17352/2022, decided on 28.08.2025), wherein the Court had held that show-cause notices issued by jurisdictional AO outside Section 151A framework are invalid, & all consequential proceedings must be quashed
High Court’s Observations
Justice S.R. Krishna Kumar observed that the present case is squarely covered by the earlier Ramachandra Reddy decision, which had categorically struck down such notices & orders issued beyond the limits of Section 151A. Accordingly, the same reasoning applied here.
