Sandeep Kumar Gupta v. UOI (2024) 300 Taxman 386 (P&H)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Jurisdiction-Notices issued by Jurisdictional Assessing Officer (JAO)-Re-assessment proceedings initiated without conducting faceless assessment as envisaged under section 144B-Contrary to provision of law-Notice and order is quashed.[S.119,120, 144B(7), 144B(8), 148, 148A(b) 148A(d), 151, Art.226]

Held that notices issued by  Jurisdictional Assessing Officer  (JAO) under section 148 and re-assessment proceedings initiated thereafter without conducting faceless assessment as envisaged under section 144B were contrary to provisions of law and  is  quashed.   Court held that exercising powers contained under sections 119 and 120, authorities could not be allowed to usurp legal provisions to their own satisfaction and convenience causing hardship to assessee.

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