Karnataka High Court invalidates reassessment notices issued contrary to Section 151A framework

Background of the dispute

The matter in Late Sri Puttamadaiah Vs ITO came before the Karnataka High Court as a challenge to a series of governmental notifications, reassessment notices, and a central instruction issued under the Income Tax Act, 1961. The assessee questioned the legality of these actions on the ground that they were contrary to the statutory mandate contained in Section 151A of the Act.

The writ petition specifically assailed:

  • Notification S.O.1432(E) [NO.20/2021/F.NO.370142/35/2020-TPL] dated 31.03.2021
  • Notification S.O.1703(E) [NO.38/2021/F.NO.370142/35/2020-TPL] dated 27.04.2021
  • Notice No. ITBA/COM/F/17/2022-23/1043047719(1) dated 17.05.2022
  • Notice No. ITBA/COM/F/17/2022-23/1043942375(1) dated 20.07.2022
  • Notice No. ITBA/AST/M/148_1/2022-23/1043961308(1) dated 20.07.2022
  • Instruction No. 1/2022 dated 11.05.2022

All of these were issued by the Revenue authorities invoking Sections 148, 148A(b) and 148A(d) of the Income Tax Act 1961.

The assessee contended that these measures were taken beyond the permissible bounds of Section 151A, which regulates the manner and conditions under which such reassessment actions can be initiated and processed.

The pivotal question before the High Court was:

Whether the impugned notifications, instructions and reassessment notices, issued under Sections 148, 148A(b) and 148A(d), were valid when they were alleged to have been issued beyond the scope and mandate of Section 151A of the Act?

This issue did not arise in isolation. The Court noted that an identical legal challenge had already been examined in W.P. No. 28182/2024 and connected matters, which had been decided on 28.08.2025. The present writ petition, therefore, turned on whether the earlier ruling would govern the present case as well.

Reference to earlier batch decision

The High Court recorded that:

  • The grounds taken in this writ petition were substantially the same as those urged in W.P. No. 28182/2024 and connected matters.
  • The core challenge in both sets of petitions related to the legality of reassessment notices and related instruments issued under Sections 148, 148A(b) and 148A(d) allegedly in violation of Section 151A.

Having noted this parity of issues, the Court concluded that the reasoning and conclusions adopted while disposing of W.P. No. 28182/2024 and connected matters would squarely apply to the present dispute.

In other words, the earlier judgment served as a binding precedent for deciding the present writ petition, as no material distinction in facts or legal grounds was demonstrated.