Taxed Before They Replied: Karnataka HC on Drone-Based Property Tax Reassessments in Bengaluru

On August 26, 2026, the Assistant Revenue Officer of the Rajajinagar sub-division signed five property tax reassessment orders against two Rajajinagar residents, one for each year from 2021-22 to 2025-26. The owners filed their reply to the show cause notices on September 23, 2026, four weeks after the orders against them had already been signed. On October 12, 2026, the Karnataka High Court quashed all five orders.

The order, in Sri N.S. Sampangiramaiah and Smt Shobha v. The Commissioner, Greater Bengaluru Authority, Writ Petition No. 31976 of 2026, is the latest of several this year in which the High Court has checked how Bengaluru's civic bodies reassess property tax under the Greater Bengaluru Governance Act, 2024. Read together with two earlier orders, it gives owners and buyers a clear picture of what the law requires before a higher tax bill can stand.

The short answer. Justice B M Shyam Prasad quashed the five reassessment orders because they were dated before the owners' reply, which the owners argued showed pre-determination. He relied on an earlier order in the same matter observing that Section 150[3] of the Act "enables the use of technology but it does not do away with the requirement of inspection of the property." In June, the court had held that drone images can start a reassessment but an officer "should have visited the property to ascertain actual measurement". In July, it held that tax on new construction can run only from the year construction was completed, subject to limitation. The trade-off: owners get a real chance to contest inflated measurements, but only if they reply on time and press for inspection.

What happened in the Rajajinagar case?

According to the October 12 order, the owners had earlier challenged show cause notices dated 29.05.2026 in Writ Petition No. 22516 of 2026. On 27.07.2026, the High Court allowed them to respond within three weeks of receiving a certified copy of that order, observing that Section 150[3] of the Act "enables the use of technology but it does not do away with the requirement of inspection of the property."

The owners filed their reply on 23.09.2026. But the reassessment orders, for the assessment years 2021-22, 2022-23, 2023-24, 2024-25 and 2025-26, were dated 26.08.2026. The order records that the second respondent had also issued notices to extend an opportunity, but the reassessment orders themselves carried the earlier date. Their counsel argued this showed pre-determination, "rendering the opportunity to the petitioner a mere formality." The court agreed that it "must favour the petitioner to quash the Reassessment Orders", and directed the second respondent, the Assistant Revenue Officer of the Rajajinagar sub-division of the West City Corporation, to give "an opportunity of personal hearing" and then decide afresh.

What did the court say about drone surveys?

In Dr. B Shekar v. The Assistant Revenue Officer, Writ Petition No. 16136 of 2026, decided on 4 June 2026, the owner held a built-up area within a larger construction. Reassessment show cause notices under Section 150(3)(e) of the Act said his property measured 4,825 square feet. He replied that the actual built-up area was only 2,500 square feet, that the 4,825 figure was "based on the images captured by drone using GIS technology", and that there must be an actual inspection.

The court said that "though the Show Cause Notices could be issued based on the images captured by drone and the assistance of the other technologies, the concerned officer should have visited the property to ascertain actual measurement", especially "when the property in question is a small portion of a larger built-up area." It quashed the assessment orders of 06.05.2026 and the demand notices, and restored the proceedings for decision "after inspection of the petitioner's property on due intimation thereof."

From which year can tax be reassessed on new construction?

In Latha M v. Greater Bengaluru Authority, Writ Petition No. 20851 of 2026, decided on 10 July 2026, the owner bought the land in 1999, got a sanctioned plan approved on 31.05.2019 and said construction, strictly as per the plan, was completed in 2021. The reassessment orders ran from 2016-17 to 2024-25, on the basis that she had built 10,143 square feet against a sanction of about 9,000 square feet.

The court found "complete non- consideration" of her detailed reply. It said: "if the petitioner is able to demonstrate that the construction is completed only in the year 2021, the assessment can only be from such period subject to the limitation on reassessment." It quashed the orders for all nine assessment years and sent the matter back with a direction to give her an opportunity before concluding the assessment.

What does Section 150 of the GBG Act allow, as the court describes it?

None of these orders reproduces the full text of Section 150, so the safest reading comes from what the court actually said about it. In the Dr. B Shekar and Latha M cases, the reassessments were proposed through show cause notices "under Section 150(3)(e)" and "Section 150[3][e]" of the Act. In the Rajajinagar case, the court's July order said Section 150[3] "enables the use of technology". Taken together, the court has accepted that technology such as drone and GIS images can be used to start reassessment, while insisting on inspection and a genuine hearing before a final order.

The Latha M order also refers to "the limitation on reassessment" without spelling it out. Owners facing reassessment for many past years should therefore ask a professional how that limitation applies to their case, rather than assume that every year in a notice can be reopened. In all three cases, the respondents were represented by the same standing counsel, who accepted notice so the petitions could be disposed of quickly. The quick disposals mean these are short orders focused on procedure, not detailed rulings on how much tax is due.

Why do these orders matter to buyers, not just owners?

Because a reassessment travels with the property. A buyer who purchases a house or a unit in a building that has received reassessment notices may inherit a dispute about built-up area, usage or the year from which tax is due. The measurement used for tax can also differ from the area in the sale deed or sanctioned plan, as these cases show.

Before buying, it is worth asking the seller whether any show cause notice or reassessment order has been issued in recent years, and checking that the property tax records reflect the built-up area you are paying for. PropNewz has explained the new civic structure and its demolition procedures in this week's report on a demolition notice deferred until appeal, and how plan deviations arise in its guide to sanctioned plan deviations.

What should an owner do when a reassessment notice arrives?

Reply in time, with documents, and ask for inspection. In each of these cases, the owner's written reply was the foundation for the court's intervention. In the Rajajinagar case, the court also noted that the owners should file a certified copy of its order within three weeks, and said "there cannot be any precipitation until there is due consideration after restoration as now permitted."

1. Note the date of the show cause notice and the area, usage or years it relies on.
2. Gather your sale deed, sanctioned plan, completion or occupancy certificate and past tax receipts.
3. Measure the built-up area, preferably with a professional, and record the method.
4. Reply in writing within the time allowed and keep proof of filing.
5. Ask specifically for a physical inspection if the figure comes from drone or GIS images.
6. If construction was completed recently, show the completion year with documents.
7. If an order is passed without considering your reply, take legal advice without delay.

Frequently asked questions

What did the Karnataka High Court decide in N.S. Sampangiramaiah v. The Commissioner on October 12, 2026?

Justice B M Shyam Prasad quashed five property tax reassessment orders dated 26.08.2026 covering 2021-22 to 2025-26 for a Rajajinagar property. The orders predated the owners' reply of 23.09.2026, which the owners said showed pre-determination. The court quashed them and directed the officer to give a personal hearing and then decide the reassessment afresh.

Can Bengaluru property tax be reassessed using drone images alone?

Not according to the High Court's June 4, 2026 order. It said show cause notices could be issued based on drone images and other technology, but the officer should have visited the property to ascertain actual measurement, especially where the property is a small portion of a larger building.

From which year can reassessed tax be charged on a new building?

In the July 10, 2026 order, the court said that if the owner can show construction was completed only in 2021, the assessment can only be from that period, subject to the limitation on reassessment. It quashed reassessment orders going back to 2016-17 and sent the matter back for reconsideration.

What should a Bengaluru owner do on receiving a reassessment show cause notice?

Note the notice date and the area or usage it alleges, reply in writing within the time given with your sanctioned plan, completion or occupancy documents and measurements, ask for a physical inspection, and keep proof of when you filed. If an order is passed without considering your reply, take legal advice promptly.

This article summarises court orders for general information and is not legal or tax advice. None of the orders decides the final tax payable.

Last updated 2026-11-07. PropNewz Team.