The notice under section 148A(b), the order under section 148A(d), and the consequent notice under section 148 were all issued by the Jurisdictional Assessing Officer (JAO) and not by a Faceless Assessing Officer (FAO). The High Court held that in terms of section 151A read with Notification No. 18/2022, dated 29-3-2022, the procedure for reassessment, including the issuance of notices under section 148A and section 148, must be conducted in a faceless manner through automated allocation. Relying on its earlier rulings, the Court found that the JAO had no jurisdiction to initiate the proceedings. Accordingly, as the very initiation was invalid, the entire proceedings were vitiated and quashed. (AY. 2017-18)
Eureka Forbes Ltd v. DCIT [2024] 168 taxmann.com 222 (Bom.)(HC)
S. 151A : Face less assessment scheme-Reassessment-Jurisdiction-Notices under sections 148 and 148A issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO)-Held to be without jurisdiction and invalid. [S.148, 148A(b), 148A(d), Art. 226]
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