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of <h1>Court Quashes Income Tax Notices: Jurisdictional Issues Under Faceless Assessment Scheme Lead to Certiorari Issuance.</h1> <h3>Royal Bitumen Private Limited, Mumbai Versus Assistant Commissioner of Income-Tax Circle 8 (1) (1) Mumbai & Ors.</h3> Royal Bitumen Private Limited, Mumbai Versus Assistant Commissioner of Income-Tax Circle 8 (1) (1) Mumbai & Ors. - TMI Issues Involved:Challenge to notice issued under Section 148A (b) of the Income Tax Act and subsequent actions taken.Analysis:1. Jurisdiction of Assessing Officer under Faceless Scheme:The petitioner challenged the notice issued under Section 148A (b) of the Income Tax Act, arguing that it was issued by the Jurisdictional Assessing Officer (JAO) in violation of the faceless scheme introduced under Section 151A of the Act. The petitioner relied on a previous judgment by the Division Bench in Hexaware Technologies Limited case, which questioned the validity of notices issued by the JAO outside the faceless assessment scheme. The court in the present case agreed with the petitioner's contention, noting that the JAO lacked jurisdiction to issue such notices under the faceless regime. The court found that the JAO's authority to issue notices under Section 148A (b) and subsequent actions under Section 148A (d) and Section 148 of the Act was superseded by the faceless assessment scheme. This issue was crucial in determining the validity of the impugned notices.2. Decision and Order:Based on the analysis of the jurisdictional issue, the court concluded that the petition should be allowed solely on the grounds related to the jurisdiction of the Assessing Officer under the faceless assessment scheme. The court ordered the issuance of a Writ of Certiorari to quash and set aside the impugned notices, including the notice under Section 148 of the Act dated April 12, 2024, the order passed under Section 148A (d) of the Act on the same date, and the notice under Section 148A (b) dated March 21, 2024. The court made the rule absolute in favor of the petitioner, without imposing any costs. The decision was based on the specific legal issue of jurisdiction under the faceless scheme, as highlighted by the petitioner and supported by relevant legal precedents.This detailed analysis of the judgment showcases the court's reasoning and decision-making process concerning the issues raised by the petitioner regarding the validity of the notices issued under the Income Tax Act and the jurisdiction of the Assessing Officer under the faceless assessment scheme.
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