Faceless reassessment notice under the CBDT regime stayed pending writ proceedings and further judicial consideration.

A notice under Section 148 of the Income-tax Act was challenged on the ground that, under the CBDT faceless regime dated 29 March 2022 read with Section 151A, it had to be issued by the Faceless Assessing Officer rather than the Jurisdictional Assessing Officer. The Bombay HC noted that the point was already covered by its earlier decision and, pending further proceedings, granted interim protection to the petitioner. Rule was issued and the impugned notice, together with all consequential proceedings, was stayed until final disposal of the writ petition.

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Issues: Whether the notice under Section 148 of the Income-tax Act, 1961 was required to be issued by the Faceless Assessing Officer under the CBDT Scheme dated 29 March 2022 under Section 151A, and whether interim stay should be granted against the impugned notice and consequential proceedings.

Analysis: The Court noted that the issue was covered by its earlier decision holding that a notice under Section 148 must conform to the CBDT faceless regime and cannot be issued by the Jurisdictional Assessing Officer. Relying on that view, the Court found it appropriate to protect the petitioner pending further proceedings, especially in view of the pendency of the said earlier decision before the Supreme Court.

Outcome: Rule was issued and interim stay was granted on the notice under Section 148 dated 29 March 2025 and all proceedings arising from it, pending the hearing and final disposal of the writ petition.

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