Jasjit Singh v. UOI (2024)467 ITR 52/ 340 CTR 1/ 240 DTR 337 / 300 Taxman 437 (P&H)(HC)

S. 147: Reassessment-Faceless Assessment-Notice-Circulars and instructions-Cannot override statutory provisions-Notice issued by Jurisdictional Assessing Officer without jurisdiction is set aside. [S. 119, 144B(7), 144B(8), 148, 151A, Art. 226]

On writ  the petitioner has challenged the notice of reassessment issued   by the Assessing Officer after the new regime of faceless assessment was brought into force by the amendment. Allowing the petitions the Court held  that notices issued by the jurisdictional Assessing Officer under section 148 and the consequent reassessment proceedings initiated under section 147 without conducting the faceless assessment in the procedure as envisaged under section 144B were contrary to the provisions of the Act and accordingly the notices and consequent order were set aside for want of jurisdiction. Relied on Jatinder Singh Bhangu v. UOI (2024) 466 ITR 474 (P& H)(HC)  E-Assessment of Income Escaping Assessments Scheme, 2022 (2022) 442 ITR (St.) 198)