Allowing the petitions, that any jurisdictional error in the notices had to be cured and hence the notices which had been issued under section 148 for reassessment under section 147 did not withstand the broader scheme of law which required automated allocation based on algorithm and random assignment of the Assessing Officer. The mandate of section 151A had to be strictly followed. The jurisdictional Assessing Officer shall not have the jurisdiction to issue notices under section 148, as it would not only render section 151A weak, but may also lead to its diminishing activation. For the purpose of notices and reassessment proceedings under sections 147, 148 and 148A and in the light of the sanction under section 151A, adherence had to be made to algorithm based random assessing system, and therefore, the notices issued under section 148 were quashed and set aside. Article 265 of the Constitution of India, prohibits the State from extracting tax from the citizens without authority of law. It is axiomatic that taxation statute has to be interpreted strictly because State cannot at its whims and fancies burden the citizens without authority of law. In a taxing statute, one has to look at the text as it is. There is no equity in taxation law. There is no intendment and presumption as to tax. Nothing is to be read in and nothing is to be implied. The basic principle of charge under the tax statutes is, “No tax can be imposed on the subject without words in the Act clearly showing an intention to lay a burden upon him. Burden of proof of bringing someone under a charge is on the Revenue and that of bringing assessee under exemption or deduction is on the assessee itself. If an interpretation of a fiscal enactment is open to doubt and two views are reasonably possible then the one more beneficial or favourable to the assessee should be adopted. Provisions related to machinery of assessment or collection should be construed to make it workable and effectuate the levy and advance the objectives of the provisions. Construction of machinery provisions that disables the taxing machinery, and enables the person to escape taxation shall be avoided. In case of provisions creating rights, courts must lean in favour of construction that saves the right instead of the one defeating it.”