CapitalG LP v ACIT (2024) 341 CTR 1024 / 165 taxmann.com 718 (Bom)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice is issued by Jurisdictional Assessing Officer and not under faceless mechanism-Notice and order is quashed. [S. 148, 148A(b) 148A(d), 151A, Art. 226]

Assessee invested an amount in compulsory convertible preference shares (CCPS) issued by an Indian company. JAO issued  notices under sections 148A and 148 seeking to reassess assessee’s income in regard to said investment. On writ the Court held that since  notice was issued by Jurisdictional Assessing Officer and not under faceless mechanism as per requirement of section 151A, same is   quashed and set aside.  (AY. 2019-20)

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