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<h1>Validity of faceless assessment notices issued by JAO instead of FAO - HC to reconsider applications citing new clarification.</h1> Validity of faceless assessment procedure where notices were issued by a subordinate assessing officer rather than the designated faceless assessment ... Validity of Faceless assessment u/s 144B - notices issued by the JAO and not FAO - HELD THAT:- We dispose of these Special Leave Petition(s) by permitting the petitioner(s) herein to file an application(s) before the High Court(s) in the disposed of matter(s) to bring to the notice of the High Court(s) the latest clarification which has been issued with effect from 01.04.2021 on such clarification to be inserted in the proposed Finance Act. If such an application(s) is made by the petitioner herein before the High Court, the same shall be considered after giving an opportunity of hearing to both sides on its merits. In the event, the petitioner or any other party is unsuccessful, then liberty is reserved to the aggrieved party(s) to approach this Court to assail the impugned order(s) as well as the subsequent order(s) to be passed. Special Leave Petitions are disposed of in the aforesaid terms. Issues: Whether the Special Leave Petitions should be disposed of by permitting the petitioner(s) to file applications before the High Court to place on record a subsequent clarification and for the High Court to consider such applications on merits.Analysis: The petitions were disposed by granting permission to the petitioner(s) to place the latest clarification (effective from 01.04.2021) before the High Court by filing an appropriate application in the disposed matters; such applications are to be considered on merits after giving an opportunity of hearing to both sides. The order preserves the right of aggrieved parties to approach this Court against the impugned or subsequent orders and disposes of all pending applications, including those seeking condonation of delay.Conclusion: Petitioners are permitted to file applications before the High Court to bring the specified clarification to its notice; the High Court shall consider such applications on merits after hearing both sides. All pending applications are disposed of.
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