The assessee challenged a notice under section 148A(b), an order under section 148A(d) and a consequent notice under section 148, arguing that they were issued by the Jurisdictional Assessing Officer (JAO) and not by a Faceless Assessing Officer (FAO). The High Court observed that the scheme notified by the Central Government under section 151A of the Income-tax Act, 1961, mandates a faceless mechanism for such proceedings. The Court rejected the Revenue’s argument that cases pertaining to ‘central charges’ were excluded from the faceless regime. Following its earlier decisions, the Court held that non-compliance with the mandatory procedure, which is in the character of subordinate legislation, vitiates the proceedings from their inception. Accordingly, the notices were held to be invalid and were quashed. (AY. 2020-21)