The Hon’ble High Court held that the CBDT issued a notification dated 29.03.2022 introducing the faceless mechanism to give effect to the provisions of section 151A of the Act. The AO is required to adhere to provisions of section 151A read with notification for passing the order under section 148A (d) and to issue notice under section 148 of the Act. Non-compliance with the scheme notified by the Central Government under section 151A (2) by the AO renders the impugned notice issued under section 148 bad in law.(AY. 2019-20)
Macleods Pharmaceuticals Ltd. v. ACIT (2024) 301 Taxman 20 (Bom.)(HC)
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless assessment-Notice issue by jurisdictional AO and not by faceless AO-Bad in law hence quashed.[S. 148, 148A(b), 148A(d), 151A, Art. 226]