Faceless reassessment procedure cannot be bypassed by circulars; notices issued without compliance were set aside.

Board instructions and circulars cannot override the statutory faceless assessment regime under the Income-tax Act, 1961, and the powers under Sections 119 and 120 cannot be used to bypass the procedure in Section 144B(7) and (8). On that basis, reassessment notices issued by the Jurisdictional Assessing Officer under Sections 148A(b), 148A(d) and 148, without following the faceless assessment procedure, were treated as contrary to the Act and without jurisdiction. The impugned notices and consequential proceedings were set aside, with liberty to proceed in accordance with the Act.

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Issues: Whether the reassessment notices and consequential proceedings issued by the Jurisdictional Assessing Officer without following the faceless assessment procedure were liable to be set aside.

Analysis: The Court followed its earlier decision holding that instructions and circulars issued by the Board cannot override statutory provisions or render them otiose. It reiterated that the powers under Sections 119 and 120 of the Income-tax Act, 1961, and Section 144B(7) and (8), cannot be used to bypass the statutory procedure. Applying that view, the notices issued under Section 148A(b), Section 148A(d) and Section 148, along with the consequential proceedings, were found contrary to the Act and without jurisdiction.

Conclusion: The impugned notices and all consequential proceedings were set aside, with liberty to proceed in accordance with the Act, 1961.

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