Faceless reassessment notice challenge secured interim stay pending writ adjudication over jurisdiction and statutory procedure.

A jurisdictional challenge was raised to a Section 148 reassessment notice issued by the Jurisdictional Assessing Officer in the context of Section 151A and the faceless assessment framework under Section 144B. The Court found a prima facie case and granted interim protection to preserve the subject matter pending adjudication of the writ petition. The impugned notice was stayed until disposal of the writ petition or until further order, whichever was earlier, and affidavits were directed to be exchanged.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 by the Jurisdictional Assessing Officer, in the context of Section 151A and the faceless assessment framework, warranted interim protection pending adjudication of the writ petition.

Analysis: The writ petition raised a jurisdictional challenge to the reassessment notice and invoked the statutory scheme under Section 151A, with reference to automated allocation and the faceless procedure contemplated in Section 144B. The Court found a prima facie case and, pending exchange of affidavits, considered it appropriate to preserve the subject-matter of the petition.

Outcome: The impugned notice was stayed until disposal of the writ petition or until further order, whichever was earlier, and affidavits were directed to be exchanged.

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