The High Court quashed reassessment proceedings initiated against the assessee. It was noted that the preliminary notice under section 148A(b), the order under section 148A(d), and the final reassessment notice under section 148 were all issued by the Jurisdictional Assessing Officer (JAO). The Court observed that the scheme notified under section 151A mandates that such proceedings be conducted by a Faceless Assessing Officer (FAO) through automated allocation. Following its earlier decision in Hexaware Technologies Ltd. v. Asstt. CIT (.) the Court held that the JAO lacked jurisdiction, rendering the entire proceedings invalid from their inception. (AY. 2016-17)
Great Eastern Shipping Co Ltd v. ACIT [2024] 167 taxmann.com 186 (Bom.) (HC)
S. 151A : Face less assessment scheme-Reassessment-Jurisdiction-Notice issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO) as required by scheme under section 151A; notice held to be without jurisdiction and quashed. [S.148, 148A(b), 148A(d), Art. 226]
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