Faceless reassessment procedure invalidated direct notices and order issued without compliance with the statutory allocation mechanism.

Faceless reassessment procedure under Section 151A is mandatory for notices under Sections 148A(b), 148A(d) and 148, and applies from initiation through the final order. Where the Jurisdictional Assessing Officer bypasses the notified faceless allocation mechanism and directly issues the reassessment notice and order, the proceedings are vitiated. No separate proof of prejudice is required once the statutory procedure is not followed. The notices and the order were therefore invalid and liable to be quashed in favour of the assessee.

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Issues: Whether the notices and order issued under Section 148A(b), Section 148A(d) and Section 148 of the Income-tax Act, 1961 were invalid for want of compliance with the faceless mechanism contemplated under Section 151A of the Act.

Analysis: The impugned proceedings were initiated by the Jurisdictional Assessing Officer instead of through the faceless allocation mechanism required by the statutory scheme notified under Section 151A. The scheme governing issuance of notice under Section 148 is mandatory and applies to the initiation stage as well as the subsequent order under Section 148A(d). Since the authority acted contrary to the prescribed procedure, the initiation of reassessment proceedings was vitiated; no separate proof of prejudice was necessary.

Conclusion: The notices and the order were invalid for non-compliance with Section 151A and were liable to be quashed, in favour of the assessee.

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