Faceless Assessing Officer requirement for reassessment notices led to annulment of the Section 148 notice and consequential proceedings.

A reassessment notice issued under Section 148 was challenged on the ground that it had been issued by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer. The High Court treated the challenge as covered by an earlier Division Bench ruling of the same Court, noted that no stay of that precedent was shown, and followed it as binding. The impugned notice and all consequential proceedings were therefore set aside, with liberty reserved to the Revenue to seek revival if the governing precedent is later reversed.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 was liable to be set aside on the ground that it had been issued by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer.

Analysis: The challenge to the reassessment notice was held to be covered by an earlier Division Bench decision of the same Court. No stay operating against that decision was shown, and the Court treated itself as bound to follow it. The impugned notice and all consequential proceedings were therefore liable to be annulled.

Conclusion: The notice under Section 148 and the proceedings/orders emanating from it were set aside, with liberty reserved to the Revenue to seek revival if the governing precedent is later reversed.

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