The assessee is a company engaged in the business of manufacturing and selling high-pressure gas cylinders. The primary issue was whether the Jurisdictional Assessing Officer (JAO) had the authority to issue notices under section 148A(b) and section 148 for the assessment year, given the provisions of section 151A and the notification dated 29-3-2022, which mandated faceless and automated allocation of such notices.

The revenue contended that the notices issued by the Jurisdictional Assessing Officer (JAO) under section 148A(b) and the subsequent order under section 148A(d) were valid and within the jurisdiction of the JAO.

The assessee argued that the notices issued by the JAO were illegal and invalid because, according to section 151A and the notification dated 29-3-2022, such notices should be issued in a faceless manner through automated allocation.  The JAO did not have the jurisdiction to issue these notices. The Hon’ble High Court held that the notices issued by the JAO were illegal and invalid.  The Hon’ble High Court emphasized that, as per section 151A and the notification dated 29-3-2022, notices under section 148 for the impugned assessment year must be issued in a faceless manner through automated allocation and that the JAO did not have the jurisdiction to issue the impugned notices. (AY. 2017-18)