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Dharmarao Kalluri Vs the Union of India — Income Tax | Andhra Pradesh HC (2026)

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Andhra Pradesh HC
2026
Dharmarao Kalluri Vs the Union of IndiaDharmarao Kalluri v. the Union of India

Allowed¶¶56

Dharmarao Kalluri v. the Union of India

Direct taxes – Income-tax assessment

Andhra Pradesh HC2 Feb 2026WP/3011/2026

Case brief

AI extract

What is this about?

Dharmarao Kalluri; APHC010715602025; W.P. Nos. 3006 & 3011 of 2026; High Court of Andhra Pradesh at Amaravati; R. Raghunandan Rao; T.C.D. Sekhar; Income Tax Act, 1961; Section 148 notice; Section 147 r.w 144 and 144B; Section 151A; faceless assessment scheme; National Faceless Assessment Centre; Jurisdictional Assessing Officer; Assessment Year 2019-20; Assessment Year 2017-18; DIN ITBA/AST/S/147/2024-25/1073786527(l); DIN ITBA/AST/S/147/2024-25/1073786485(l); Prameela Pasumarthi Vs. CIT; 2025 SCC Online AP 4052; assessment set aside; writ allowed; mandamus; Article 226.

What did the court decide?

Both writ petitions allowed; the notices dated 03.04.2023 and 20.03.2024 issued by the 2nd respondent and all consequential proceedings set aside; respondent authorities left free to initiate and complete assessments in accordance with law; no order as to costs; pending miscellaneous applications closed.

Why is it important?

Following the Division Bench ruling in Prameela Pasumarthi Vs. CIT, both writ petitions are allowed: the Section 148 notices dated 03.04.2023 and 20.03.2024 issued by the 2nd respondent and all consequential proceedings (including the final assessment orders dated 27.02.2025) are set aside. ¶¶56

What the court decided

AI extract

Outcome

Both writ petitions allowed; the notices dated 03.04.2023 and 20.03.2024 issued by the 2nd respondent and all consequential proceedings set aside; respondent authorities left free to initiate and complete assessments in accordance with law; no order as to costs; pending miscellaneous applications closed.

Issue for consideration

Whether the final assessment orders dated 27.02.2025 for Assessment Years 2019-20 and 2017-18 are without jurisdiction and violative of Section 151A of the Income Tax Act, 1961, having been initiated by notices issued by the Jurisdictional Assessing Officer rather than through the faceless system.

Court's answer

Following the Division Bench ruling in Prameela Pasumarthi Vs. CIT, both writ petitions are allowed: the Section 148 notices dated 03.04.2023 and 20.03.2024 issued by the 2nd respondent and all consequential proceedings (including the final assessment orders dated 27.02.2025) are set aside.

Detailed headnote1 paragraphs

Direct taxes – Income-tax assessment – Notices u/s 148 of the Income Tax Act, 1961 dated 03.04.2023 and 20.03.2024 issued by the Jurisdictional Assessing Officer for AY 2019-20 and AY 2017-18; assessments completed under the faceless system by final orders dated 27.02.2025 u/s 147 r.w 144 and 144B – Held, initiation by the Jurisdictional Assessing Authority violates the mandatory provisions of Section 151A, which mandates that all assessments be initiated and completed only through the faceless system – Following the Division Bench common-order ruling in Prameela Pasumarthi Vs. CIT (2025 SCC Online AP 4052), both writ petitions allowed; the Section 148 notices and all consequential proceedings, including the final assessment orders dated 27.02.2025, set aside – Liberty reserved to the respondent authorities to initiate and complete assessments in accordance with law – No order as to costs.

A

APHC010715602025

[3529]

IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI

(Special Original Jurisdiction)

TUESDAY, THE THIRD DAY OF FEBRUARY TWO THOUSAND AND TWENTY SIX

PRESENT

THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO

THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR

WRIT PETITION Nos.3006 & 3011 of 2026

WRIT PETITION NO: 3006/2026

Between:

DHARMARAO KALLURI, , S/O. SAMBAMURTY KALLURI, AGED 53 YEARS, R/O. PARAPURAM, PARAPURAM VILLAGE, SALIVEEDHI KOTTURU TALUKA, SRIKAKULAM, 532455, ANDHRA PRADESH.

...PETITIONER

AND

THE UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, G7X2 H7V, NEHRU PLACE, NEW DELHI, DELHI 110019 2.

THE INCOME TAX OFFICER, INCOME TAX DEPARTMENT WARD 1, SRIKAKULAM, ANDHRA PRADESH, 532001 3.

THE ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MAYUR BHAWAN, CONNAUGHT LANE, CONNAUGHT PLACE, NEW DELHI 110001.

...RESPONDENT(S):

Petition under Article 226 of the Constitution of India praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased toPleased In the facts and circumstances of the instant case, to issue a Writ, Order or Direction more particularly one in the nature of a Writ of Mandamus, declaring the impugned notice issued by the 2nd Respondent u/s

2

RRR,J & TCDS,J W.P.Nos.3006 & 3011 of 2026

148 of the Act bearing DIN and Notice No. ITBA/AST/S/148_l/202324/1051861021(1) dated 03 - 04 - 2023 and the Final Assessment Order U/s. Sections 147 r.w 144 and 144B of the Act, bearing DIN No. ITBA/AST/S/147/2024-25/1073786527(l) dated 27 - 02 - 2025 for the Assessment Year 2019-20 as arbitrary, illegal, bad in law, issued without jurisdiction and as against the law laid down by this Honble High Courts common order in Writ Petition No. 14681 of 2023 and batch dated 28 - 10 - 2025 and to consequently set aside the same and pass

IA NO: 1 OF 2026

Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased pleased Pending adjudication of the above Writ Petition, to further stay all the proceedings inpursuance of the Final Assessment Order U/s. Sections 147 r.w 144 and 144B of the Act, bearing DIN No. ITBA/AST/S/147/202425/1073786527(l) dated 27 - 02 - 2025 for the Assessment Year 2019-20 and pass

WRIT PETITION NO: 3011/2026

Between:

DHARMARAO KALLURI, S/O. SAMBAMURTY KALLURI, AGED 53 YEARS, R/O. PARAPURAM, PARAPURAM VILLAGE, SALIVEEDHI KOTTURU TALUKA, SRIKAKULAM, 532455, ANDHRA PRADESH.

...PETITIONER

AND

THE UNION OF INDIA, REPRESENTED BY ITS SECRETARY, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, G7X2 PLUS H7V, NEHRU PLACE, NEW DELHI, DELHI 110019

THE INCOME TAX OFFICER, INCOME TAX DEPARTMENT WARD 1, SRIKAKULAM, ANDHRA PRADESH, 532001

THE ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, MAYUR BHAWAN, CONNAUGHT LANE, CONNAUGHT PLACE, NEW DELHI 110001.

3

RRR,J & TCDS,J W.P.Nos.3006 & 3011 of 2026

...RESPONDENT(S):

Petition under Article 226 of the Constitution of India praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased topleased to issue a Writ, Order or Direction more particularly one in the nature of a Writ of Mandamus, declaring the impugned Notice issued by the Respondent No. 2 U/s 148 of the Income Tax Act, 1961 bearing DIN and Notice No. ITBA/AST/S/148_l/2023-24/l062978426(1) dated 20 - 03 - 2024 and the Final Assessment Order U/s. Sections 147 r.w 144 and 144B of the Act, bearing DIN No. ITBA/AST/S/147/2024-25/1073786485(l), dated 27 - 02 - 2025, passed by the Respondent No. 3 for the Assessment Year 2017-18, as arbitrary, illegal, bad in law, issued without jurisdiction and as against the law laid down by this Honble High Court's common order in Writ Petition No. 14681 of 2023 and batch dated 28 - 10 - 2025 and to consequently set aside the same and pass

IA NO: 1 OF 2026

Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased pleased Pending adjudication of the above Writ Petition, to further stay all the proceedings in pursuance of the Final Assessment Order U/s. Sections 147 r.w 144 and 144B of the Act, bearing DIN No. ITBA/AST/S/147/202425/1073786485(1), dated 27 - 02 - 2025, passed by the Respondent No. 3 for the Assessment Year 2017- 18 and pass

Counsel for the Petitioner:

1.T PRADYOTH

Counsel for the Respondent(S):

1.ANUP KOUSHIK KARAVADI

4

RRR,J & TCDS,J W.P.Nos.3006 & 3011 of 2026

The Court made the following Common Order:

(per Hon’ble Sri Justice R. Raghunandan Rao)

As both these Writ Petitions have been filed by the same petitioner and raise the similar issue, they are being disposed of, by way of this common order.

The assessment proceedings were initiated against the petitioner, for the assessment year, 2019-2020, and for the assessment year, 2017-2018, by way of separate notices, under Section 148 of the Income Tax Act, 1961, (herein referred to as ‘the Act’) , dated 03.04.2023 & 20.03.2024. The proceedings initiated by these notices, culminated in a separate final assessment order, dated 27.02.2025. The show-cause notices were issued by the Jurisdictional Assessing Officer, while the assessments were completed under the faceless systems.

The petitioner being aggrieved by these two orders of assessment, dated 27.02.2025, has approached this Court, with the contention that, the said orders of assessment are without jurisdiction and are violative of Section 151A of the Act.

A Division Bench of this Court in the case of Prameela Pasumarthi Vs. CIT¹ and following the judgments of various other Hon’ble High Courts, had held that, any assessment initiated by issuance of notices, by the Jurisdictional Assessing Authority, would be violative of the mandatory

1 2025 SCC Online AP 4052

5

RRR,J & TCDS,J W.P.Nos.3006 & 3011 of 2026

provisions of Section 151A of the Act, in as much as the said provision mandates that all such assessments should only be initiated and completed through the faceless systems.

Following the said judgment, these Writ Petitions are allowed, setting aside the notices, dated 03.04.2023 & 20.03.2024, issued by the 2^nd respondent and all consequential proceedings. However, they shall be open to the respondent authorities to initiate and complete assessments, in accordance with Law. There shall be no order as to costs.

As a sequel, pending miscellaneous applications, if any, shall stand closed.

________________________

R. RAGHUNANDAN RAO, J

_________________

T.C.D. SEKHAR, J

Date:03.02.2026 KPV

6

RRR,J & TCDS,J W.P.Nos.3006 & 3011 of 2026

184

THE HON’BLE SRI JUSTICE R. RAGHUNANDAN RAO

AND

THE HON'BLE SRI JUSTICE T.C.D.SEKHAR

WRIT PETITION Nos.3006 & 3011 of 2026

(per Hon’ble Sri Justice R. Raghunandan Rao)

03.02.2026

KPV

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the final assessment orders dated 27.02.2025 for Assessment Years 2019-20 and 2017-18 are without jurisdiction and violative of Section 151A of the Income Tax Act, 1961, having been initiated by notices issued by the Jurisdictional Assessing Officer rather than through the faceless system.¶¶50
The court held
Following the Division Bench ruling in Prameela Pasumarthi Vs. CIT, both writ petitions are allowed: the Section 148 notices dated 03.04.2023 and 20.03.2024 issued by the 2nd respondent and all consequential proceedings (including the final assessment orders dated 27.02.2025) are set aside.ratio¶¶56

Cases cited

Colour shows how this judgement treated each authority

AI extract

Prameela Pasumarthi Vs. CITFollowed¶¶51
2025 SCC Online AP 4052 · Who else cites this

Statutes considered

5 provisions across 3 enactments

AI extract

Constitution of IndiaArticle 226¶¶19
CPC151¶¶24
Income Tax Act, 1961148¶¶36 147 r.w 144 and 144B¶¶36 151A¶¶50

Procedural history

How this case reached the court

AI extract

Order under challenge
Final Assessment Orders dated 27.02.2025 under Sections 147 r.w 144 and 144B of the Income Tax Act, 1961 for Assessment Year 2019-20 (DIN No. ITBA/AST/S/147/2024-25/1073786527(l)) and Assessment Year 2017-18 (DIN No. ITBA/AST/S/147/2024-25/1073786485(l)), together with the originating Section 148 notices dated 03.04.2023 and 20.03.2024, challenged as arbitrary, illegal, without jurisdiction and contrary to the common order in W.P. No. 14681 of 2023 and batch.¶¶36
Passed by Respondent No. 3 (Assessment Unit, National Faceless Assessment Centre) · 2025-02-27
Prior proceeding
Separate notices under Section 148 of the Income Tax Act, 1961 dated 03.04.2023 and 20.03.2024 initiated assessment proceedings against the petitioner for AY 2019-2020 and AY 2017-2018 respectively, culminating in final assessment orders dated 27.02.2025.¶¶49
Prior proceeding
Show-cause notices in the assessments were issued by the Jurisdictional Assessing Officer, while the assessments themselves were completed under the faceless system.¶¶49

Parties & counsel

AI extract

petitioner
Dharmarao Kalluri¶¶12
T PRADYOTH
respondent
The Union of India, represented by its Secretary, Department of Revenue, Ministry of Finance¶¶15
ANUP KOUSHIK KARAVADI
respondent
The Income Tax Officer, Income Tax Department Ward 1, Srikakulam¶¶16
ANUP KOUSHIK KARAVADI
respondent
The Assessment Unit, National Faceless Assessment Centre, Income Tax Department¶¶17
ANUP KOUSHIK KARAVADI

Coram

AI extract

R. Raghunandan Raoauthor¶¶47
T.C.D. Sekharmember¶¶8

Case details

As recorded by the court registry

Court: Andhra Pradesh HC
Decided on: 2 Feb 2026 · February
Registered: 2 Feb 2026
Case no.: WP/3011/2026
CNR: APHC010715492025
Topic: Income Tax
Bench: R Raghunandan Rao T.c.d.sekhar
Disposal: ALLOWED NO COSTS
Case type: WRIT PETITION

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Cite this judgement

Dharmarao Kalluri v. the Union of India, WP/3011/2026 (AP), decided on 2 February 2026.

The High Court of Andhra Pradesh publishes no neutral citation for this judgement — cite it by case number and date of decision.

Cases cited1

Prameela Pasumarthi Vs. CITFollowed¶¶51

Open Authorities

Statutes5

Constitution of IndiaArticle 226
CPC151
Income Tax Act, 1961148 · 147 r.w 144 and 144B · 151A

View all statutes

Procedural history3

Final Assessment Orders dated 27.02.2025 under Sections 147 r.w 144 and 144B of the Income Tax Act, 1961 for Assessment Year 2019-20 (DIN No. ITBA/AST/S/147/2024-25/1073786527(l)) and Assessment Year 2017-18 (DIN No. ITBA/AST/S/147/2024-25/1073786485(l)), together with the originating Section 148 notices dated 03.04.2023 and 20.03.2024, challenged as arbitrary, illegal, without jurisdiction and contrary to the common order in W.P. No. 14681 of 2023 and batch.Passed by Respondent No. 3 (Assessment Unit, National Faceless Assessment Centre) · 2025-02-27
Separate notices under Section 148 of the Income Tax Act, 1961 dated 03.04.2023 and 20.03.2024 initiated assessment proceedings against the petitioner for AY 2019-2020 and AY 2017-2018 respectively, culminating in final assessment orders dated 27.02.2025.
Show-cause notices in the assessments were issued by the Jurisdictional Assessing Officer, while the assessments themselves were completed under the faceless system.

View full history

Bench / Coram

R. Raghunandan Rao and T.C.D. Sekhar

Parties & counsel