(i) The Jurisdictional Assessing Officer (JAO) does have ‘exclusive powers’ to issue notice under Section 148 of the Income Tax Act, 1961. Both the JAO and the Faceless Assessing Officer (FAO)will have concurrent powers for ‘assessment, re-assessment and re-computation’ of the particular income in a faceless manner.

(ii) The Directorate of IT (Systems) shall have the power to make allotment of cases, through the AAS, to allot the cases for issuance of notice under Section 148 A and 148 in eligible cases based on the risk management strategy in terms of the provisions of the E-Assessment of Income Escaping Assessment Scheme, to the JAO based on the PAN card jurisdiction.

(iii) The issuance of the impugned notice was duly in accordance with the Scheme, except the procedural lapse of mentioning the name of the JAO, as the Directorate of Income Tax (Systems) allotted the cases through the AAS based on the risk management strategy for issuing the notice in faceless manner.

(iv) The procedural errors will “not vitiate” the initiation of the proceedings for issuance of the notice under Section 148 of IT Act since such errors are curable in nature.

Hexaware Technologies Limited vs. Assistant Commissioner of Income Tax and others reported in 2024 SCC OnLine Bom 1249. Kankanala Ravindra Reddy vs. Income-Tax Officer reported in (2023) 156 taxmann.com 178 T.K.S.Builders Private Limited vs. Income Tax Officer rendered in W.P.(C).No.1968 of 2023 Talati and Talati LLP vs. Office of Assistant Commissioner of Income Tax reported in 2024: GUJHC: 54567-DB referred.