Air India Ltd v. ACIT [2024] 166 taxmann.com 345 (Bom.)(HC)

S. 151A: Face less assessment scheme-Reassessment-Jurisdiction-Notice-Notice under section 148A(b), order under section 148A(d) and consequent notice under section 148 issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO)-Without jurisdiction and invalid. [S.148, 148A(b), 148A(d), Art. 226]

The High Court quashed reassessment proceedings initiated by the Jurisdictional Assessing Officer (JAO) through a notice under section 148A(b), an order under section 148A(d), and a final notice under section 148. It was held that as per section 151A and the mandatory faceless scheme notified thereunder, jurisdiction for such actions vests exclusively with a Faceless Assessing Officer (FAO) through automated allocation. The Court, relying on its own precedent, ruled that since the JAO lacked the requisite jurisdiction, the entire proceedings were vitiated and invalid from inception. (AY. 2016-17)

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