On writ the Court held that the notice under section 148A and order passed thereon were issued by Jurisdictional Assessing Officer (JAO) and not by a Faceless Assessing Officer (FAO), as required by provisions of section 151A, reducing “faceless assessment” to assessment by JAO by means of E-Proceedings might not constitute assessment in a faceless manner, thus, matter was to be referred to a Division/ Larger Bench on question of jurisdiction of JAO to conduct proceeedings under section 148A. (AY. 2015-16)
TVS Credit Services Ltd v. Dy. CIT (2025) 481 ITR 574/ 174 taxmann.com 1078 (Mad)(HC)
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless assessment-Jurisdiction lies with Faceless Assessment Officer or Jurisdictional Assessing Officer-Contrary views in precedents-Decision in Mark Studio India Pvt. Ltd. v. ITO1 dissented from Matter referred to Division or larger Bench.[S. 144B, 147, 148, 148A, 151A, Art. 226]
Leave a Reply