Section 148 Notice Invalidated for Genuine Non-Filing of Return

Siddaraju Vs ITO (Karnataka High Court) Reassessment & Penalty Orders Set Aside Due to Non-Filing of Return for Bona Fide Reasons; Fresh Opportunity Granted The Karnataka High Court, in Sri Siddaraju vs. Income Tax Officer & Ors. (W.P. No. 37468 of 2025, order dated 11-Dec-2025), set aside the reassessment order u/s 147 r/w ss.144 & 144B and the consequential penalty orders u/s 271(1)(b), 271(1)(c) & 271F for AY 2014-15, holding that the Assessee was denied a meaningful opportunity to comply with the reassessment proceedings. The Court accepted the Assessee’s explanation that...