Faceless reassessment notice validity and jurisdictional time-bar objections require appellate review alongside the merits of the addition.

Validity of a reassessment notice under the faceless reassessment framework, the statutory time limit for challenging jurisdiction, and the merits of the addition require adjudication by the appellate authority. The matter was remitted for determination of these issues in accordance with the jurisdictional High Court decision when rendered. The appellate authority must therefore examine both the jurisdictional objections to the notice and the substantive basis for the addition.

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Issues: Whether the validity of the reassessment notice in light of the faceless reassessment scheme and the objection under the statutory time limit for challenging jurisdiction required fresh adjudication; and whether the appellate authority should also decide the addition on merits.

Outcome: The matter was remitted to the appellate authority to adjudicate the validity of the notice under the faceless reassessment framework, the objection under the jurisdictional time bar, and the merits of the addition, in accordance with the decision of the jurisdictional High Court when rendered.

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