ITAT issues guidelines for stay of demand.
Quote from: satyanveshi on May 07, 2026, 11:42:06 AMThe retrospective amendment made JAO FAO issue of sec 151A and consequential notification and recent amendment made in sec. 147A was not viewed properly by the stake holders. To start with the newly inserted section is reproduced hereunder..
"147A. Notwithstanding anything contained in any judgement, order
or decree of any court or in section 151A or in any scheme framed
thereunder, for the removal of doubts, it is hereby clarified that the
Assessing Officer for the purposes of sections 148 and 148A shall mean
and shall always be deemed to have meant to be an Assessing Officer other
than the National Faceless Assessment Centre or any assessment unit
referred to in sub-section (3) of section 144B.".
A hormonious reading of 151A and the above mentioned 147A, what we understand is....
Issuance notices u/s 148A and 148 are also in Faceless manner through automated allocation... Of course, for both these sections the officer need not be assessment Unit or NafAc... Ok JAO ( or any other officer ) also but what about the restriction imposed in sec 151A....faceless manner and automated allocation.... This restriction enacted by sec 151A is nowhere removed by enacting 147A....
Then what newly inserted 147A really communicates... AO (other than NafAc or AU) is empowered to issue these Notices of 148A and 148 in a faceless manner through automated allocation...