The High Court quashed a reassessment notice under section 148 and the underlying order under section 148A(d), holding them to be without jurisdiction. It ruled that section 151A, in conjunction with the CBDT scheme dated 29.03.2022, establishes a mandatory faceless regime where jurisdiction is exclusively vested in the FAO through an automated allocation system. Relying on its earlier judgment in Hexaware Technologies Ltd., the Court affirmed that the JAO has no concurrent jurisdiction to initiate such proceedings. An action taken by an authority contrary to the statute is inherently prejudicial and invalid from inception. (AY. 2020-21)