Dismissing the petition the Court held that Office Memorandum dt. 20th Feb., 2023 being F. No. 370153/7/2023-TPL issued by the CBDT has clarified that the JAO as well as units under NFAC have concurrent jurisdiction and therefore, impugned notice under s. 148 is not invalid on the ground that the same has been issued by the JAO and not by National Faceless Assessment Centre as per S. 151A. (AY. 2019-20)
Triton Overseas (P) Ltd. v. UOI [2023] 156 taxmann.com 318 / (2024) 338 CTR 535 (Cal)(HC)
S.151A : Faceless assessment of income escaping assessment-Reassessment-Notice issued by jurisdictional Assessing Officer and not as per S. 151A-Office Memorandum dt. 20th Feb., 2023 being F. No. 370153/7/2023-TPL issued by the CBDT has clarified that the JAO as well as units under NFAC have concurrent jurisdiction-Notice under S. 148 is not invalid on the ground that the same has been issued by the JAO and not by National Faceless Assessment Centre as per S. 151A. [S. 148, Art. 226]
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