On a writ petition challenging initial notice under section 148A(b), the order under section 148A(d) and the consequent notice issued under section 148 by the jurisdictional Assessing Officer for the assessment year 2017-18 on the ground that they were invalid and without jurisdiction since they were in contravention of the provisions of section 151A read with section 144B and the Scheme notified by the Central Government vide notification dated March 29, 2022 ([2022] 442 ITR (St.) 198) under section 151A whereunder the Revenue was under a mandate to follow the faceless mechanism, in resorting to any procedure under section 148A to issue notice under section 148 by the jurisdictional Assessing Officer. Allowing the petition the Court held that,  (i) that the contention that the category of cases as notified under order(s) dated March 31, 2021 and September 6, 2021 issued under section 119 providing for exclusion of cases assigned to the Central and International taxation charges from the applicability of section 144B was concerned, could not be accepted to be the correct position in law. Firstly, the order dated March 31, 2021 issued under sub-section (2) of section 144B of the Act and order dated September 6, 2021 issued under section 119 applied only in respect of assessment orders to be passed, as clearly seen from the content of both such orders. Secondly, the Scheme notified under section 151A under notification dated March 29, 2022 ([2022] 442 ITR (St.) 198) applying the procedure of faceless mechanism to the proceedings under section 148A and section 148 was neither subject to the applicability of the prior order dated March 31, 2021 read with September 6, 2021 nor was it explicit so as to include the applicability of these orders to the Scheme as notified under section 151A. Thirdly, it would be doing violence to the language of the notification or Scheme dated March 29, 2022 ([2022] 442 ITR (St.) 198) to read into such notification what had not been expressly provided for or something which was kept outside the purview of the notifications dated March 31, 2021 and September 6, 2021. It would be uncalled for and also not appropriate for the court to read into the Scheme dated March 29, 2022 ([2022] 442 ITR (St.) 198), something which is not included. It could not be said that the Central Government was not aware as to what was provided for in the notifications dated March 31, 2021 and September 6, 2021 so as to not include it under the Scheme dated March 29, 2022 ([2022] 442 ITR (St.) 198). It would thus be not correct, that the court had read into the Scheme dated March 29, 2022 ([2022] 442 ITR (St.) 198) the applicability of notifications dated March 31, 2021 and September 6, 2021. Such approach would also be contrary to the mandate of section 151A and to the Scheme framed thereunder. Accepting the Revenue’s contention to read into the Scheme as contained in the notification dated March 29, 2022 ([2022] 442 ITR (St.) 198), the applicability of the order dated March 31, 2021 and September 6, 2021 would amount to not only rewriting such Scheme issued by the Central Government but reading something into the provisions of section 151A which the Legislature itself had not provided for. Section 151A and the Scheme notified below it stood independent under the notification dated March 31, 2022.  Followed  Hexaware Technologies Ltd. v. ACIT (2024) 464 ITR 430 (Bom)(HC)  Capitalg LP  v. ACIT   (IT) (2024) 468 ITR 325 (Bom)(HC) T. Venkataramana Reddy Patloola v. Dy. CIT (2024) 468 ITR 181 (Telangana (HC)  wherein the Courts have  consistently held that in respect of Central charges and International taxation charges, the proceedings under section 148A read with section 148 of the Act would be required to be held in a faceless manner, applying the provisions of section 144B and as effected under the provisions of section 151A read with the Scheme notified by the Central Government vide notification dated March 29, 2022 ([2022] 442 ITR (St.) 198). Accordingly  the assessee’s case would not fall outside the applicability of the provisions of section 151A and the Scheme. Hence the initial notice issued under section 148A(b), the order passed under section 148A(d) and the consequent notice issued under section 148 by the jurisdictional Assessing Officer fell outside the purview of the faceless mechanism and hence were illegal and without jurisdiction and accordingly set aside. (AY. 2017-18)