Faceless reassessment notice challenge secured interim stay pending affidavits on a prima facie jurisdictional objection.

A writ petition challenged a reassessment notice under the Income-tax Act on the ground that it should have been issued in faceless form under Section 151A, and the maintainability issue was left open. The court found a prima facie jurisdictional objection and, relying on an earlier Division Bench order, granted interim protection pending a fuller hearing on affidavits. The impugned notice was stayed until December 2024 or further orders, whichever was earlier, and affidavits were directed to be exchanged.

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Issues: Whether the writ petition challenging the notice issued under Section 148 of the Income-tax Act, 1961, including the objection that it ought to have been issued in a faceless manner under Section 151A, required interim protection pending exchange of affidavits.

Analysis: The petition raised a jurisdictional objection and kept the question of maintainability open. Taking note of the prima facie case and the cited Division Bench order, interim protection was considered appropriate pending a fuller hearing on affidavits.

Outcome: The impugned notice was stayed until December 2024 or until further orders, whichever is earlier, and affidavits were directed to be exchanged.

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