Faceless reassessment notices must follow the statutory regime from the notice stage, limiting jurisdiction of the Assessing Officer.

A notice under Section 148 issued by the jurisdictional Assessing Officer was considered challengeable for lack of jurisdiction because the faceless assessment regime was treated as applying from the notice stage itself. The analysis applied the CBDT notification dated 29.03.2022 and Section 151A to conclude that issuance of the notice falls within the faceless mechanism, and that assessment proceedings begin with the show-cause notice stage. It also reaffirmed that administrative instructions or circulars cannot override the statutory mandate.

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Issues: Whether a notice issued under Section 148 of the Income-tax Act, 1961 by the jurisdictional Assessing Officer was without jurisdiction in view of the CBDT notification dated 29.03.2022 and the faceless assessment scheme.

Analysis: The issue was treated as covered by earlier coordinate bench decisions holding that the faceless assessment scheme applies from the stage of notice under Section 148 and that, under Section 151A read with the notification dated 29.03.2022, issuance of such notice falls within the faceless mechanism. It was further applied that assessment proceedings commence from the stage of show-cause notice, and that administrative instructions or circulars cannot override the statutory mandate.

Conclusion: The notice under Section 148 was held to be assailable on the ground of lack of jurisdiction in light of the applicable faceless assessment regime.

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