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PNB MetLife India Insurance Company Limited Vs ACIT (Karnataka High Court)
Karnataka HC quashes reassessment notices issued to PNB MetLife – follows Ramachandra Reddy ruling on Sec.151A jurisdiction
The Petitioner, PNB MetLife India Insurance Company Ltd. filed a writ petition challenging the order u/s 148A(3) and the reassessment notice u/s 148—both dated 29.06.2025—issued by the ACIT, Circle-5(1)(1), Bengaluru for AY 2019-20.
The Petitioner contended that the notices were issued without jurisdiction, as they violated the framework prescribed under Section 151A of the Income-tax Act governing authorization and procedure for faceless reassessment.
The Revenue defended the initiation of proceedings.
Justice S.R. Krishna Kumar noted that the matter was directly covered by the Co-ordinate Bench decision in Ramachandra Reddy Ravi Kumar v. DCIT (WP No.17352/2022 & batch, dated 28.08.2025), wherein the Court had held that show-cause notices issued beyond the scope of Section 151A are void and all subsequent proceedings stand quashed.
Accordingly, the Court held that the impugned notices & consequential orders suffered from the same jurisdictional defect and therefore deserved to be quashed on identical grounds.
Held
- Petition allowed, following Ramachandra Reddy Ravi Kumar (supra).
- Order u/s 148A(3) and notice u/s 148, both dated 29.06.2025, quashed as being beyond the authority of law under Sec.151A.
- Liberty granted to the Revenue to seek revival after the Supreme Court’s decision in pending matters on the same issue.
- All rival contentions kept open, and no opinion expressed on merits.
This ruling extends the series of Karnataka HC judgments (including Navnidhi Infrastructure Pvt. Ltd., Bangalore International Airport Ltd., etc.) applying Ramachandra Reddy Ravi Kumar. It reinforces that any reassessment notice issued by a non-jurisdictional or unauthorized officer under the faceless regime contravenes Section 151A and is void ab initio, pending the Supreme Court’s final verdict on the issue.
FULL TEXT OF THE JUDGMENT/ORDER OF KARNATAKA HIGH COURT
In this petition, the petitioner seeks the following reliefs:
“a) Quashing the order dated 29.06.2025 bearing DIN and Notice No. TBA/AST/F/148A/2025-26/1077984254(1) (Annexure-L) passed by the 1st Respondent under Section 148A(3) of the Act for the assessment year 2019-20;
b) Quashing of the notice dated 29.06.2025 bearing DIN and Notice No.ITBA/AST/S/148-1/2025-26/ 1077984268(1) (Annexure-N) passed by the 1st Respondent under Section 148 of the Act for the assessment year 2019-20;
(c) Pass such other or further orders as this Hon’ble Court may deem fit in the facts and circumstances of the case, in the interests of justice and equity.
2. Heard learned 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 counsel for the petitioner invited my attention to the order of a Coordinate 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, in order to contend that the present petition deserves to be allowed and disposed of in terms of the said order.
4. Per contra, learned counsel for the respondents submits that there is no merit in the petition and that the same is liable to be dismissed.
5. As rightly contended by the learned counsel for the petitioner the present petition is directly and squarely covered by the 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, the operative portion of which reads as under:
“13. I, therefore, pass the following:
O R D E R
(i) The impugned show cause notices issued by the jurisdictional Assessing Officer outside the scope of Section 151-A of the Act stand obliterated. All further proceedings initiated thereto, challenged in these cases would stand quashed.
(ii) Liberty is reserved to the respondents – revenue to revive all these petitions in the event the Apex Court would hold in favour of the Revenue in the pending before it.
(iii) With the aforesaid liberty and to the aforesaid extent, the petitions are allowed.
(iv) Contentions of both the parties except the one noted hereinabove, shall remain open to be considered in the event revival of these petitions would become necessary.”
6. The aforesaid order is applicable to the facts and circumstances of the instant case and consequently, the present petition also deserves to be disposed of in terms of the judgment of co-ordinate Bench of this Court in Ramachandra Reddy’s case (supra).
7. In the result, I pass the following:
ORDER
(i) The petition is allowed and disposed of in terms of the 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.
(ii) The impugned show cause notice and consequential order at Annexure-L and Annexure-N both dated 29.06.2025 are hereby quashed.
(iii) Liberty is reserved in favour of the respondents – Revenue to seek revival of this petition, subsequent to disposal of the matters pending before the Apex Court and all rival contentions between the parties in this regard are kept open and no opinion is expressed on the same.
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