Faceless reassessment notice requirement under Section 151A: notice issued by jurisdictional officer held void and quashed.

Reassessment notice under Section 148 and the preceding order under Section 148A(d) must be issued through the faceless mechanism mandated by Section 151A and the notified scheme. Where both were issued by the Jurisdictional Assessing Officer instead of by the Faceless Assessing Officer through automated allocation, the action was contrary to the prescribed procedure and therefore invalid. The notice and underlying order were held void for want of jurisdiction, and the reassessment proceedings were quashed in favour of the assessee.

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Issues: Whether a notice for reassessment under Section 148 of the Income-tax Act, 1961, along with the underlying order under Section 148A(d), is valid when issued by the Jurisdictional Assessing Officer instead of through the faceless mechanism mandated by Section 151A.

Analysis: The reassessment scheme under Section 151A, as implemented through the notified faceless framework, governs the issuance of notice under Section 148 as well as the prior procedure under Section 148A. The record showed that both the notice and the order were issued by the Jurisdictional Assessing Officer and not through the Faceless Assessing Officer mechanism. In view of the binding interpretation that issuance of such notice is required to be through automated allocation and in a faceless manner, action taken contrary to the prescribed procedure is invalid.

Conclusion: The notice and the underlying order were jurisdiction and invalid; the challenge succeeded and the impugned proceedings were quashed in favour of the assessee.

Ratio Decidendi: Where the statute and the notified scheme require reassessment notice under Section 148 to be issued through the faceless mechanism, a notice issued by the Jurisdictional Assessing Officer in breach of that mandate is void and liable to be set aside.

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