The Jurisdictional Assessing Officer (JAO) issued a reassessment notice under section 148 of the Act for AY 2018-19, despite the mandate under section 151A of the Act that such notices must be issued by a Faceless Assessing Officer (FAO). The assessee challenged the validity of the notice before the Hon’ble Bombay High Court. The High Court held that under the Scheme notified pursuant to section 151A, reassessment proceedings must be initiated in a faceless manner unless specifically excluded. The notice issued by the JAO, instead of the FAO, was contrary to the prescribed procedure and, therefore, without jurisdiction. Since the reassessment proceedings were vitiated at the foundation itself, the consequential reassessment order and related proceedings could not be sustained.

Accordingly, the reassessment notice, reassessment order, and all consequential proceedings were quashed.(AY. 2018-19)