CBDT vide order dated 31.03.2021 under section 144B(2) had held that the faceless mechanism would also be applicable to cases of Central Charges and International Taxation charges and it is only the assessment proceedings which would be required to be undertaken outside the faceless mechanism. Thus, the notice issued under section 148 of the Act by JAO and not under faceless mechanism as required under section 151A is bad in law.(AY. 2017-18)
Abhin Anilkumar Shah v. ITO, IT (2024) 301 Taxman 156 /341 CTR 1033 (Bom.)(HC)
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Face less assessment-Central charge-International taxation charges-Faceless mechanism would also be applicable to cases of Central Charges and International Taxation charges-Notice issued by JAO is bad in law. [S.144B(2) 148, 151A]