The assessee challenged a notice issued under section 148 of the Income-tax Act, 1961, and the preceding order under section 148A(d), on the ground that they were issued by the Jurisdictional Assessing Officer (JAO) and not the Faceless Assessing Officer (FAO). The High Court, following its earlier decision in Hexaware Technologies Ltd, held that Section 151A, read with the scheme notified on 29.03.2022, mandates that proceedings under section 148 and section 148A must be conducted in a faceless manner. This vests exclusive jurisdiction with the FAO. Consequently, the actions taken by the JAO were without jurisdiction and invalid. The High Court accordingly quashed the impugned notices and order. (AY. 2017-18)
Godrej and Boyce Manufacturing Co Ltd v. ACIT [2024] 166 taxmann.com 686 (Bom.) (HC)
S. 151A : Face less assessment scheme-Reassessment-Jurisdiction-Notice issued by Jurisdictional Assessing Officer-As per scheme notified under Section 151A, exclusive jurisdiction vests with Faceless Assessing Officer-Notice issued by Jurisdictional Assessing Officer held invalid and quashed. [S. 148, 148A(b), 148A(d) Art. 226]
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