The assessee challenged a reassessment notice issued under Section 148 and the preceding order under Section 148A(d) on the ground that they were issued by the Jurisdictional Assessing Officer (“JAO”) and not a Faceless Assessing Officer (“FAO”). The High Court, following its own recent decision in Hexaware Technologies Ltd v. ACIT [2024] 162 taxmann.com 225 (Bom.)(HC), held that for a reassessment notice to be valid, the Revenue must comply with the mandatory scheme notified under Section 151A. This scheme requires that notices be issued by an FAO through an automated allocation system, and it confers exclusive jurisdiction on the FAO for this purpose, leaving no concurrent jurisdiction with the JAO. Since the JAO lacked the legal authority to issue the notice, the action was contrary to law and invalid from its inception, vitiating the entire proceedings. Accordingly, the Court quashed the impugned notice and order. (AY. 2017-18)