Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Validity of Faceless assessment u/s 144 r.w.s.144B - The High Court observed that the impugned order indeed failed to comply with the prescribed procedure under Section 144B of the Act. The absence of a proceeding shifting the assessment from the Central Assessment Circle to the regular assessment circle, as well as the failure to issue notices u/s 143(2) and 144B(1)(iii) of the Act, rendered the order invalid. The High Court observed that the combination of show cause notice and draft assessment order into a single document was procedurally incorrect. The court referenced a previous ruling that such a combination was impermissible, undermining the statutory framework designed to ensure transparency and accountability in assessments.
Validity of Faceless assessment u/s 144 r.w.s.144B - The High Court observed that the impugned order indeed failed to comply with the prescribed procedure under Section 144B of the Act. The absence of a proceeding shifting the assessment from the Central Assessment Circle to the regular assessment circle, as well as the failure to issue notices u/s 143(2) and 144B(1)(iii) of the Act, rendered the order invalid. The High Court observed that the combination of show cause notice and draft assessment order into a single document was procedurally incorrect. The court referenced a previous ruling that such a combination was impermissible, undermining the statutory framework designed to ensure transparency and accountability in assessments.
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