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IN THE HIGH COURT OF KARNATAKA AT BENGALURU
S.R. KRISHNA KUMAR
Exotic Innovations Private Limited – Appellant
Versus
Deputy Commissioner Of Income Tax – Respondent
| Table of Content |
|---|
| 1. summary of reliefs sought by petitioner. (Para 1) |
| 2. petitioner’s arguments on assessment orders. (Para 2 , 3 , 4 , 5 , 6) |
| 3. court observations on precedents and jurisdiction. (Para 7 , 8 , 9) |
| 4. decisions should align with established precedents. (Para 10) |
ORDER :
S.R.KRISHNA KUMAR, J.
In this petition, petitioner seeks for the following reliefs:
"The Petitioner, therefore, prays that this Hon'ble Court be pleased to issue a writ, order or direction:
Assessment Year 2017-18
a) quashing the notice dated 17.12.2024 issued under Section 148 of the Act by the 1st Respondent, bearing DIN ITBA/AST/S/148_1/2024-25/1071279362(1) (Annexure A), for the assessment year 2017-18;
b) quashing the assessment order dated 02.05.2024 (to be read as 02.05.2025) passed by the 1st Respondent bearing DIN ITBA/AST/M/147/2025-26/1076024080(1) (Annexure B), and the rectified order dated 03.07.2025 passed by the 1 Respondent bearing DIN ITBA/REC/M/154/2025- 26/1078190268(1) (Annexure B-3), for the assessment year 2017-18;
c) quashing the demand notice dated 02.05.2025 issued under Section 156 of Act by the 1st Respondent bearing DIN ITBA/AST/M/147/2025-26/1076024167(1) (Annexure B-1), and the de
The authority of jurisdictional Assessing Officers to issue notices under Section 148 post-faceless scheme is invalid, as it contravenes procedural mandates outlined in the Income Tax Act.
The jurisdiction of the Assessing Officer to issue notices under the Income Tax Act post-faceless regime is invalid, rendering the resulting assessments void.
Jurisdiction for initiating proceedings under the Income Tax Act must comply with prescribed legal frameworks; failure to do so invalidates subsequent orders.
The jurisdiction of the Assessing Officer to issue notices under the Income Tax Act is annulled if the action violates procedural norms established by recent legislative changes.
The jurisdiction for issuing notices under Section 148 post-Faceless Scheme lies solely with the faceless assessing officer, making actions taken by jurisdictional officers invalid.
Jurisdiction of the Income Tax Assessing Officer to issue notices post-Faceless Scheme's implementation is invalid as established by previous judgments, rendering subsequent orders quashed.
Assessing Officer lacks jurisdiction to issue notices post-faceless assessment scheme under Income Tax Act; all related proceedings quashed.
The court affirmed that assessment proceedings initiated without jurisdiction under Section 148 post-Faceless Scheme are void, quashing all relevant notices and orders.
Jurisdiction of the Assessing Officer under the Income Tax Act is limited post-implementation of the Faceless Scheme, invalidating notices issued under Section 148 after March 29, 2022.
The court ruled that assessments initiated by non-designated officers post-faceless scheme were illegal, underscoring the need for jurisdictional compliance under the Income Tax Act.
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