Faceless assessment notice must come from the Faceless Assessment Officer; jurisdictional officer's notice was quashed.

Under the faceless assessment regime, a notice must be issued by the Faceless Assessment Officer, not by the Jurisdictional Assessing Officer. Applying that view, the High Court found the impugned notice unsustainable and quashed it. The Court also left the parties' rights and contentions open, including liberty to seek revival if the governing precedent is later reversed by the Supreme Court.

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Issues: Whether a notice issued by the Jurisdictional Assessing Officer instead of the Faceless Assessment Officer was valid.

Analysis: The Court followed the view that, under the faceless assessment regime, the concerned notice must be issued by the Faceless Assessment Officer and not by the Jurisdictional Assessing Officer. In the absence of any stay against that view, the notice issued in the present petition was held to be unsustainable. The Court also kept open the parties' rights and contentions, including liberty to seek revival if the governing precedent is reversed by the Supreme Court.

Conclusion: The notice was quashed and set aside, and the issue was decided in favour of the assessee.

Final Conclusion: The petition was disposed of by granting relief to the assessee on the notice-issuance issue, while leaving other matters open where not covered by the governing precedent.

Ratio Decidendi: Under the faceless assessment regime, a notice must be issued by the Faceless Assessment Officer, and a notice issued by the Jurisdictional Assessing Officer is invalid.

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