The High Court held that for a notice for reassessment under Section 148 to be validly issued, the Revenue must comply with the faceless assessment scheme notified pursuant to Section 151A. The Court clarified that this scheme grants exclusive jurisdiction to the Faceless Assessing Officer (FAO) to issue such notices through an automated allocation process, and there is no concurrent jurisdiction vested in the Jurisdictional Assessing Officer (JAO). In the instant case, since the notice under Section 148 and the underlying order under Section 148A(d) were issued by the JAO, the proceedings were initiated without proper jurisdiction. The High Court, therefore, quashed the impugned notice and order. (AY. 2014-15)
Leave a Reply