Reassessment notices under Sections 148A(b) and 148, faceless regime, proceedings stayed pending challenge to jurisdiction

SC considered a challenge to reassessment notices issued u/s 148A(b) and 148 on the ground that, post CBDT Notification dated 29.03.2022 mandating faceless reassessment, only the Faceless Assessing Officer and not the Jurisdictional Assessing Officer could initiate such proceedings. The HC had held this issue to be covered against the assessee by an earlier decision. SC issued notice on the special leave petition, returnable in four weeks, and permitted dasti service. Pending further consideration, SC directed that the reassessment proceedings shall remain stayed until the next date of hearing.

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The Supreme Court issued an interim order in a matter concerning ongoing assessment proceedings. It directed that notice be issued to the respondent, making it returnable in four weeks, thereby initiating formal adjudicatory process. The Court further permitted "dasti service, in addition," allowing the petitioner to effect personal/hand-delivery service of notice to expedite and ensure effective service on the respondent in the absence of representation. Crucially, the Court ordered that "the assessment proceedings shall remain stayed till the next date of hearing," granting interim protection to the petitioner against continuation or conclusion of the assessment. The stay remains operative pending further orders on the next date of hearing.

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