Pursuant to a search on the Seksaria Group, the Assessing Officer reopened the assessments of The Estate Investment Company Pvt. Ltd. for several years and made additions towards alleged capital gains and unexplained money on the basis of seized diaries and employee statements. The assessee contended that the notice under section 148 was issued by the Jurisdictional AO instead of the Faceless AO as required under section 151A, and that the assessment order dated 27-03-2023 was manually issued without a pre-generated DIN, contrary to CBDT Circular No. 19/2019, which mandates electronic generation and quoting of DIN on all communications. The Tribunal held that the faceless reassessment scheme confers exclusive jurisdiction on the Faceless AO, and any notice issued by the Jurisdictional AO is coram non judice and void. Further, since the assessment order contained a manually written DIN and no exceptional circumstances or prior approval were recorded as prescribed by the Circular, the order was non est and deemed never to have been issued. The reassessments were accordingly quashed as void ab initio. Followed , Ashok Commercial Enterprises v. ACIT [(2023) 154 Taxmann.com 144 (Bom)(HC)  Hexaware Technologies Limited v. ACIT  [2024] 464 ITR 430 (Bom)(  HC) ,Abhin Anil Kumar Shah v. ITO [(2024) 468 ITR 350 (Bom)(HC)  Ganesh Nivrutti Jagtap v. ACIT [(2024) 166 Taxmann.com 168 (Bom)( HC) The dismissal of the Special Leave Petition by the Hon’ble Supreme Court in Deepanjan Roy v. ADIT [SLP (C) No. 18753/2025] (ITA Nos. 3012–3013 & 3222–3228/Mum/2025 dt. 17-10-2025)  ( AY. 2014-15 to 2022-23)