The High Court held that a notice for reopening assessment under section 148 must be issued by a Faceless Assessing Officer (FAO) in compliance with section 151A and the Scheme dated 29-3-2022. A notice issued by the Jurisdictional Assessing Officer (JAO) is without jurisdiction and foundationally defective, which vitiates the entire proceedings. Consequently, the High Court quashed the defective notice, the subsequent reassessment order, and any consequential demand or penalty notices. It was held that the filing of an appeal by the assessee against the reassessment order could not cure this fundamental jurisdictional defect. (AY. 2019-20)