Ashni Logistics Pvt. Ltd v. ACIT (2025) 476 ITR 684 (Bom)(HC)

S. 151A: Face less assessment scheme-Notice under section 148 issued by jurisdictional Assessing Officer instead of Faceless Assessing Officer-Non-compliance with provisions of section 151A-Notice invalid.[S. 147, 148, 148A(b), 148A(d), Art.226]

Held that that the notice issued under section 148 and the order under section 148A(d) were issued by the jurisdictional Assessing Officer and not by the Faceless Assessing Officer, as required under the provisions of section 151A of the Act. The jurisdictional Assessing Officer had no jurisdiction to issue the notices under sections 148A(b) and 148. In view of the law in Hexaware Technologies Ltd. v. Asst. CIT, (2024) 464 ITR 430 (Bom); (2024) 2 HCC (Bom) 204, the notice was unsustainable and consequently, the very manner in which the proceedings were initiated, vitiated the proceedings. The notices and consequent order were quashed. (AY. 2020-21)

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