The petitioner challenged the notice dated 28 March 2024 under section 148 alleging violation of section 151(1) and claiming the Department intended to conduct proceedings in a non-faceless manner. The Court observed that a subsequent notice dated 28 June 2024 under section 148 clarified the reassessment would be completed under the faceless procedure (section 144B) and that all proceedings would be conducted electronically through the assessee’s e-proceedings account. The initial notice of 28 March 2024 merely indicated the Department’s intention to reopen for faceless reassessment. The assessee was required to file responses via the online portal (and did so); there was no indication the Department intended to bypass faceless procedure. Accordingly, the petition was dismissed.(SJ)