Faceless reassessment procedure prevails over instructions, and notices issued without section 144B compliance were set aside.

Notices issued under section 148A(b), the order under section 148A(d), the notice under section 148, and the consequential reassessment proceedings were held unsustainable where earlier binding decisions had already found such action contrary to the Income-tax Act, 1961. The Court followed its prior ruling and the coordinate bench view that circulars or instructions cannot override statutory provisions, and that reassessment initiated by the Jurisdictional Assessing Officer without following the faceless assessment procedure under section 144B was contrary to the statutory scheme. The impugned notices and proceedings were therefore set aside.

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Issues: Whether the notice under section 148A(b), the order under section 148A(d), the notice under section 148, and the consequential proceedings were sustainable when the challenge was covered by earlier binding decisions holding such action to be contrary to the Income-tax Act, 1961.

Analysis: The Court followed its earlier decision and the coordinate bench view that circulars or instructions cannot override statutory provisions. It accepted that proceedings initiated by the Jurisdictional Assessing Officer without adhering to the faceless assessment procedure under section 144B were contrary to the scheme of the Act. The notices and subsequent action were thus treated as having been issued without authority in law.

Conclusion: The impugned notice under section 148A(b), the order under section 148A(d), the notice under section 148, and the consequential proceedings were set aside.

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