Validity of faceless assessment notices issued by JAO instead of FAO - HC to reconsider applications citing new clarification.

Validity of faceless assessment procedure where notices were issued by a subordinate assessing officer rather than the designated faceless assessment officer was left open: petitioners were permitted to file applications before the High Court to place a newly issued clarification (effective 01.04.2021) on record, and the High Court must decide those applications on merits after hearing both sides; unsuccessful parties retain liberty to approach this Court to challenge the impugned and any subsequent orders. Special leave petitions were disposed of on these procedural terms, directing reconsideration in light of the clarification.

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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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