Allowing the petitions the Court held that  to the limited extent, that according to the plain and unambiguous language used in the Gazette notification dated March 29, 2022 ([2022] 442 ITR (St.) 198) (Scheme) and Central Board of Direct Taxes order dated September 6, 2021 the notice under section 148 did not fall within the “exception” stated in the order of the Central Board of Direct Taxes wherein direction was issued about passing of “assessment orders” by the National Faceless Assessment Centre under section 144B except in two situations, one of which was passing of assessment orders in cases assigned to international tax charges. The taxpayer was nowhere distinguished between non-residents and residents. The notice issued under section 148 must comply with the requirement of the scheme whether or not the taxpayer was a non-resident or a resident. The expression used in clause 3(b) of the scheme dated March 29, 2022 ([2022] 442 ITR (St.) 198) did not preclude the mandatory faceless assessment procedure for issuance of notice under section 148. The Revenue had erred in not following such procedure and since the notices under section 148 were not issued as prescribed, the subsequent proceedings on these notices and consequent assessment orders were vitiated and accordingly, set aside. Liberty was given to the Revenue to proceed in accordance with law.