Faceless reassessment procedure governs Section 148 notices; jurisdictional officer action without it was held invalid.

Reassessment notices under Sections 148A(b), 148A(d) and 148 were treated as invalid where they were issued by the Jurisdictional Assessing Officer instead of through the faceless mechanism required by Section 151A. The Court applied the notified scheme governing faceless reassessment and held that notice under Section 148 and the preceding Section 148A steps must follow that statutory allocation of jurisdiction. Because the impugned notices, order and consequential assessment action were not issued in compliance with the prescribed procedure, the initiation of proceedings was contrary to law and could not be sustained.

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Issues: Whether notices and orders issued for reassessment under Sections 148A(b), 148A(d) and 148 of the Income-tax Act, 1961 were valid when they were issued by the Jurisdictional Assessing Officer instead of through the faceless mechanism mandated by Section 151A of the Act.

Analysis: The challenge concerned the legality of reassessment proceedings initiated for the relevant assessment year. The Court applied the scheme introduced under Section 151A and the binding interpretation that, for notice under Section 148 and related steps under Section 148A, jurisdiction must be exercised in the faceless manner contemplated by the notified scheme. Since the impugned notices, order and consequential assessment action were issued by the Jurisdictional Assessing Officer and not in compliance with the faceless allocation mechanism, the initiation of proceedings was contrary to law and could not be sustained. The Court also noted that when an authority acts contrary to the prescribed statutory procedure, invalidity follows without the assessee having to prove further prejudice.

Conclusion: The reassessment notices and consequential proceedings were held invalid and were quashed, with the petition allowed in favour of the assessee.

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