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.

ORAL ORDER

In this Petition, petitioner seeks the following reliefs: "Wherefore it is prayed that this Hon'ble Court be pleased to:

a) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the assessment order dated 27.09.2023 passed under section 147 of the Income Tax Act, 1961 for the Assessment Year 2018-19 by the Respondent No.1 bearing DIN & Order No. ITBA/AST/S/147/2023-24/1056652389(1) herein marked as Annexure - A1.

b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 27.09.2023 for the Assessment Year 2018-19 issued by the Respondent No.1 bearing DIN & Document No. ITBA/AST/5/186/2023-24/1056652443(1) herein marked as Annexure - A2.

c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand dated 27.09.2023 issued under section 156 of the Income Tax Act, 1961 for the Assessment Year 2018-19 by the Respondent No.1 bearing DIN & Notice No. 1764/A51/5/156/2023-24/1056652450(1) herein marked as Annexure A3.

d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 29.09.2023 issued under section 274 r.w.s. 270A of the Income Tax Act, 1961 for the Assessment Year 2018-19 by the Respondent No.1 bearing 1056654019(1) herein marked as Annexure - A4. DIN NO.ITBA/PNL/5/270円/1423-24/

e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice dated 04.07.2022 issued under section 148 of the Income Tax Act, 1961 for the assessment year 2018-19 by the Respondent No.1 bearing DIN & Notice No. ITBA/AST/S/148_1/2022- 23/1043723408(1) marked as Annexure - B. herein

f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the appellate order dated 28.02.2025 passed under section 250 of the Income Tax Act, 1961 for the assessment year 2018-19 by the Respondent No.3 bearing DIN No. ITBA/APL/M/250/2024- 25/1073648516(1) herein marked as Annexure - C.

g) Issuing appropriate directions to the Income Tax Appellate Tribunal, Bangalore Bench, Bengaluru in relation to the appeal pending before it in ITA No. 1272/Bang/2025 for the A.Y. 2018-19.

h) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity."

2. Heard learned Senior Counsel for the Petitioner and learned counsel for the respondents and perused the material on record.

3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned Senior Counsel for the petitioner submitted that pursuant to the impugned notice under section 148 of the Income Tax Act, 1961 at Annexure - B dated 04.07.2022, the respondent No.1 completed the assessment proceedings and passed the Assessment Order dated 27.09.2023 determining the total income of the petitioner as Rs.155,05,33,950/-.

4. Aggrieved by the said Assessment Order, the petitioner has preferred an appeal before the third respondent - appellate authority which dismissed the appeal vide final order dated 28.02.2025. Aggrieved by the same, the petitioner has approached the Income Tax Appellate Tribunal, Bengaluru Bench, ITA No.1272/BANG/25, which is pending adjudication.

5. Meanwhile, decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income-tax - W.P.No.17352/2022 and connected matters - dated 28.08.2025, has disposed of the petitions quashing the show cause notice on the ground that the Assessing Officer did not have jurisdiction to issue the notice under section 148 of the Act in the light of Section 151A of the Income Tax Act, 1961 and t