Deepanjan Roy v. Add. DIT (2025) 478 ITR 158 (Telengana)(HC) Editorial : SLP of revenue dismissed, Add. DIT (IT) v. Deepanjan Roy (2025) 478 ITR 160 (SC)

S. 148A: Reassessment-Reassessment-Conducting inquiry, providing opportunity before issue of notice-International transactions-Face less assessment scheme-Must be by faceless procedure-Notices not following faceless procedure quashed.[S. 144B, 148, 148A(b), 148(A)(d), Art. 226]

Allowing the petition the Court held, that issue was covered by the decision of the court in Venkataramana Reddy Patloola v. Dy. CIT (2024) 468 ITR 181 (Telengana)(HC), holding that the phrase “to the extent provided in section 144B of the Act” in clause 3(b) of the e-Assessment of Income Escaping Assessment Scheme, 2022 dated March 29, 2022 ((2022) 442 ITR (St.) 198) does not preclude the mandatory faceless procedure for issuance of notice under section 148 of the Income-tax Act, 1961, and quashing the notices on the ground that they had not been issued in a faceless manner, the writ petition was allowed.

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