Faceless reassessment mandate breached by jurisdictional initiation, rendering notices and consequential orders invalid under the amended tax scheme.

Reassessment notices issued under Sections 148A and 148, and the consequential orders, were treated as unsustainable because they were not initiated through the faceless mechanism mandated by the amended Income-tax Act framework and the applicable Section 151A notification. The Court noted that the jurisdictional Assessing Officer had commenced the proceedings instead of the prescribed faceless process, which constituted a jurisdictional illegality. In view of the settled position followed by other High Courts, the notices and resulting orders were quashed, and the Revenue was left to proceed only in accordance with the lawful mechanism.

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Issues: Whether the notices issued under Section 148A and Section 148 of the Income-tax Act, 1961, and the consequential proceedings and orders, were liable to be quashed for not being initiated in a faceless manner in terms of Section 151A of the Act and the applicable notification.

Analysis: The challenge was confined to the jurisdictional objection that reassessment proceedings were initiated by the jurisdictional Assessing Officer instead of through the faceless mechanism mandated after the Finance Act, 2021 regime. The Court noted that the same issue had already been decided by this Court and by several other High Courts, holding such proceedings to be contrary to the amended statutory scheme and the notification issued under Section 151A. It further recorded that no interim protection had been granted by the Supreme Court in the pending SLPs, and that the Revenue had continued to initiate identical proceedings despite the settled position. On that basis, the Court treated the impugned notices and the consequential orders as unsustainable.

Conclusion: The reassessment notices and the consequential orders were quashed as invalid, and the writ petition was allowed in favour of the assessee on the jurisdictional issue.

Final Conclusion: The proceedings were set aside because the reassessment machinery was invoked contrary to the faceless procedure contemplated by the amended law, leaving the Revenue free to proceed only in accordance with the lawful mechanism.

Ratio Decidendi: Where the statute and the applicable notification require reassessment to be undertaken through the faceless mechanism, initiation of proceedings by the jurisdictional Assessing Officer in breach of that mandate is a jurisdictional illegality that vitiates the notices and all consequential orders.

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