Reassessment notice issued under sections 148 and 148A by Jurisdictional Assessing Officer (JAO) instead of a Faceless Assessing Officer (FAO) is in contravention of section 151A and faceless mechanism introduced by Central Government vide Notification dated 29 March 2022 and therefore the said notices are invalid.(AY. 2020-21)
Sahib Singh Agencies (Bombay) (P.) Ltd. v. Dy. CIT (2024) 301 Taxman 150 (Bom.)(HC)
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice issued by JAO is in contravention of faceless mechanism provided under section 151A-is bad in law.[S.148, 148A(b) 148A(d) 151A, Art. 226]