Faceless reassessment procedure controls initiation under the Income-tax Act; jurisdictional officer notices were set aside as invalid.

Reassessment notices and related proceedings initiated by the Jurisdictional Assessing Officer after the faceless assessment scheme under Section 151A came into force were treated as lacking jurisdiction. The Court applied its earlier coordinate bench ruling and other jurisdictional High Court decisions to hold that, once the faceless mechanism was operative, initiation under Sections 148A and 148 by the jurisdictional officer was not sustainable. The impugned notices, orders and consequential proceedings were therefore set aside as jurisdictionally defective in favour of the assessee.

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Issues: Whether proceedings initiated under Sections 148A and 148 of the Income-tax Act, 1961 by the Jurisdictional Assessing Officer after the faceless scheme came into force were without jurisdiction and liable to be set aside.

Analysis: The proceedings in all the writ petitions were initiated after 29.03.2022, when the faceless assessment scheme had come into force under Section 151A of the Income-tax Act, 1961. The Court treated the controversy as already settled by its earlier coordinate bench decision and by other jurisdictional High Court decisions, and found that the initiation of reassessment proceedings by the Jurisdictional Assessing Officer instead of the faceless mechanism was not sustainable. On that basis, the impugned notices, orders, and consequential proceedings were held to suffer from a jurisdictional infirmity.

Conclusion: The initiation of proceedings under Sections 148A and 148 of the Income-tax Act, 1961 by the Jurisdictional Assessing Officer was held to be invalid, and the impugned proceedings were set aside in favour of the assessee.

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