In this case, the Supreme Court addressed the validity of reassessment proceedings initiated under Section 148 of the Income-tax Act for Assessment Year 2018-19. The assessee had challenged the validity of the reassessment notice and the order under Section 148A (d) on the ground that they were issued by the Jurisdictional Assessing Officer and not through the mandatory faceless mechanism prescribed under Section 151A, as notified by the Central Government on 29 March 2022.The Bombay High Court held that compliance with Section 151A was essential for issuing a valid notice under Section 148, and since the impugned notices were not in accordance with the faceless scheme, they were invalid and liable to be set aside. Additionally, the High Court also observed that the reassessment was initiated after the expiry of three years from the end of the relevant assessment year, and therefore, sanction for issuing the notice should have been obtained from the higher authorities specified under Section 151(ii) and not from lower-ranked authorities under Section 151(i). The Revenue filed a Special Leave Petition before the Supreme Court, which was dismissed on account of gross delay of 248 days in filing the petition as well as on merits.(AY. 2018-19)