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Notice issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessment Officer (FAO) u/s 148A(b) for income escaping assessment is invalid. Faceless assessment scheme notified u/s 151A mandates automated allocation and faceless assessment u/s 144B. JAO lacked jurisdiction to issue notice outside faceless assessment procedure. Assessing Officer also failed to consider assessee's submission regarding project completion method while reopening assessment. Assessee's appeal allowed by High Court on grounds of invalidity of notice and non-consideration of submissions.
Notice issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessment Officer (FAO) u/s 148A(b) for income escaping assessment is invalid. Faceless assessment scheme notified u/s 151A mandates automated allocation and faceless assessment u/s 144B. JAO lacked jurisdiction to issue notice outside faceless assessment procedure. Assessing Officer also failed to consider assessee's submission regarding project completion method while reopening assessment. Assessee's appeal allowed by High Court on grounds of invalidity of notice and non-consideration of submissions.
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