Vanitha Govindappa Vs ITO (Karnataka High Court)
Karnataka HC quashes reassessment for AY 2020-21 as AO acted beyond scope of Section 151A; Revenue liberty kept open pending SC verdict
The Karnataka High Court (Justice M. Nagaprasanna) quashed the reassessment proceedings initiated against the Petitioner for AY 2020-21, holding that the show-cause notices issued by the jurisdictional AO were beyond the scope of Section 151A of the Income-tax Act, 1961.
The Petitioner had challenged a series of proceedings — including two notices u/s 148A(b) dated 23.03.2024 & 31.03.2024, an order u/s 148A(d) dated 12.04.2024, and a subsequent reassessment notice u/s 148 issued on the same date. It was contended that the jurisdictional officer had no authority to issue such notices, as the same were required to be initiated by the faceless regime under Section 151A.
The Court observed that the grounds raised were identical to those already considered in W.P. No. 28182/2024 & connected batch, disposed of on 28.08.2025, wherein similar reassessment proceedings were struck down on the same jurisdictional infirmity.
Following the earlier ruling, the Court held that the impugned show-cause notices & consequential reassessment proceedings stood obliterated. However, it granted liberty to the Revenue to revive the proceedings if the Supreme Court, in the pending matter, eventually decides in its favour.
