Authority: High Court of Karnataka, Bengaluru

Order Date: 28 August 2025

Case Overview

  • Petition No. 9353 of 2024 (T‑IT) filed by Mysore District Judicial Employees Credit Co‑operative Society Limited, represented by its President Sri M. V. Sheshadri, seeking quashing of multiple Income‑Tax orders for Assessment Year 2015‑16.
  • Respondents: Assessment Unit, Income Tax Department; Additional/Joint/Deputy/Assistant Commissioners of Income‑Tax, including the Commissioner of Income‑Tax, Karnataka & Goa.
  • The petitioner challenged: (i) Assessment order under Section 147 RWS 144B dated 28/02/2024 (DIN ITBA/AST/S/147/2023‑24/1061691231(1)); (ii) Computation sheet dated 28/02/2024 (DIN ITBA/AST/S/115/2023‑24/1061691370(1)); (iii) Demand notice under Section 156 dated 28/02/2024 (DIN ITBA/AST/S/156/2023‑24/1061691281(1)); (iv‑viii) Penalty notices under Section 274 RWS 271(1)(c), 271(1)(b), 271A, 271B, 271F dated 28/02/2024 with respective DINs ITBA/PNL/S/271(1)(c)/2023‑24/1061691410(1), ITBA/PNL/F/271(1)(b)/2023‑24/1061691409(1), ITBA/PNL/S/271A/2023‑24/1061691407(1), ITBA/PNL/S/271B/2023‑24/1061691408(1), ITBA/PNL/S/271F/2023‑24/1061691426(1); (ix‑xii) Notices and order under Section 148A(b), 148A(d) and Section 148 dated 23/03/2022 and 04/04/2022 (DINs ITBA/AST/F/148A(SCN)/2021‑22/1041313880(1), ITBA/AST/F/148A/2022‑23/1042486771(1), ITBA/AST/S/148_1/2022‑23/1042486965(1)).
  • The grounds raised were identical to those in W.P. No. 28182/2024, which the Court disposed of on 28‑08‑2025.

Final Outcome

1. The show‑cause notice issued by the jurisdictional Assessing Officer, being outside the scope of Section 151‑A, is declared obliterated; all further proceedings based on it are quashed.

2. The revenue is granted liberty to revive the petition should the Apex Court later rule in its favour.

3. With the above liberty, the petition is allowed.

4. All other contentions of the parties, except the point noted above, remain open for consideration. IA No.1/2024 may be revisited if revival of the petition becomes necessary.

Topics: Tax Assessment, Judicial Review