SSTA Logistics India Private Limited Vs ACIT (Karnataka High Court)
Summary: The Karnataka High Court allowed a batch of writ petitions challenging reassessment notices issued under Sections 147 and 148 of the Income-tax Act, 1961 and quashed the impugned notices along with all consequential proceedings. The petitions concerned reassessment proceedings for AY 2008-09 and/or AY 2010-11, as applicable to the respective writ petitions.
The petitioners submitted that the reassessment notices had been issued consequent to the Justice M.B. Shah Enquiry Commission Report on illegal mining of iron and manganese. In support, they relied upon the coordinate Bench decision of the Karnataka High Court in M/s. Deccan Mining Syndicate Private Limited Vs. Deputy Commissioner of Income Tax, WP No.16256/2016 dated 17.10.2025, NE:2025:KHC:41997. The Court recorded that the coordinate Bench, while dealing with a similar factual situation, had considered the Bombay High Court judgment in Sesa Sterlite Limited Vs. Assistant Commissioner of Income Tax, (2019) 417 ITR 334, as well as the Allahabad High Court judgment in Mudra Exports Vs. Deputy Commissioner of Income Tax, Writ Tax No.628/2015 dated 05.04.2024.
The High Court further noticed that the judgment in Sesa Sterlite Limited had been challenged before the Supreme Court in Assistant Commissioner of Income Tax Vs. M/s. Venture Real Estate and Another, Special Leave to Appeal No.4575/2020 dated 05.03.2025, and that the challenge was rejected. The relevance of the Sesa Sterlite ruling to reassessment based on the Shah Commission Report has also been recognised in subsequent proceedings; in Ashapura Minichem Limited Vs DCIT, the Mumbai ITAT applied the Bombay High Court ruling where reopening was entirely based on the Justice M.B. Shah Commission Report.
