Reliance Jio Infocomm Ltd v. DCIT [2024] 165 taxmann.com 547 (Bom.)(HC)

S. 151A : Face less assessment scheme-Reassessment-Jurisdiction-Under the scheme notified pursuant to Section 151A, a notice for reassessment can only be issued by a Faceless Assessing Officer (FAO) through automated allocation; a notice issued by the Jurisdictional Assessing Officer (JAO) is without jurisdiction and invalid. [S.148, 148A(b), 148A(d), Art. 226]


The assessee challenged a reassessment notice under Section 148, arguing it was issued by the Jurisdictional Assessing Officer (JAO) and not by a Faceless Assessing Officer (FAO) as mandated by the faceless assessment scheme. The High Court, following its earlier judgment in Hexaware Technologies Ltd, affirmed that the scheme notified under Section 151A is mandatory. It held that the jurisdiction to issue a notice under Section 148 is exclusively vested with an FAO through automated allocation, to the complete exclusion of the JAO. Since the notice was issued by an authority lacking jurisdiction, the High Court quashed the notice and the connected proceedings as invalid from the outset. (AY. 2017-18)

Leave a Reply

Your email address will not be published. Required fields are marked *

*