The assessee challenged reassessment proceedings on the ground that the notice under section 148A(b), the order under section 148A(d) and the consequent notice under section 148 were all issued by the Jurisdictional Assessing Officer (JAO). The High Court observed that as per the scheme notified on 29.03.2022 pursuant to section 151A, such proceedings must be conducted in a faceless manner by a Faceless Assessing Officer (FAO). Since the JAO lacked jurisdiction to issue the notices and pass the order, the Court held that the initiation of proceedings was contrary to the prescribed legal procedure and was consequently invalid. Accordingly, the notices and the order were quashed. (AY. 2017-18)
Bank of India v. ACIT [2024] 167 taxmann.com 75 (Bom.)(HC)
S. 151A : Face less assessment scheme-Reassessment-Jurisdiction-Notices and order under sections 148A and 148 issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO) as required by scheme under section 151A-Proceedings held invalid and without jurisdiction. [S.148, 148A(b), 148A(b),Art. 226]
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