Faceless reassessment notices must follow the statutory faceless mechanism; notices issued otherwise are without jurisdiction.

Reassessment notices issued under Sections 148 and 148A(1) were treated as invalid where the faceless assessment scheme and the CBDT notification dated 29.03.2022 required issuance through the National Faceless Assessment Centre. The court applied earlier co-ordinate bench decisions holding that the scheme under Section 151A governs the stage of notice issuance, and that departmental circulars, instructions, or office memoranda cannot override the statutory mandate. On that jurisdictional basis, the impugned notices were not sustained, and the challenge to reassessment succeeded, leaving the revenue to proceed only in accordance with law.

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Issues: Whether notices issued under Section 148 and Section 148A(1) of the Income-tax Act, 1961 were invalid for want of jurisdiction because the faceless assessment scheme and the CBDT notification dated 29.03.2022 required issuance by the National Faceless Assessment Centre.

Analysis: The writ petition was disposed of in terms of earlier co-ordinate bench decisions on the same issue. Those decisions held that the faceless assessment scheme applies from the stage of notice under Sections 148 and 148A, that the scheme under Section 151A and the notification issued thereunder governs issuance of such notices, and that departmental circulars, instructions, or office memoranda cannot override the statutory mandate. On that basis, the jurisdiction of the issuing authority to issue the impugned notices was found lacking.

Conclusion: The challenge to the reassessment notices succeeded, and the matter was disposed of in line with the earlier decisions, leaving the revenue free to proceed only in accordance with law.

Final Conclusion: The impugned notices were not sustained on the jurisdictional objection, and the petition stood disposed of by applying the settled faceless reassessment regime.

Ratio Decidendi: Where the statute and the notified faceless assessment scheme require issuance of reassessment notices through the designated faceless mechanism, a notice issued otherwise is without jurisdiction, and administrative instructions cannot displace the statutory procedure.

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