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The High Court held that the notice u/s 148 of the Income Tax Act issued on April 4, 2022, was beyond the prescribed period of limitation, rendering the consequent actions illegal. Mere issuance of a notice u/s 148A for conducting an inquiry before issuing a notice u/s 148 cannot be read within the ambit of the first proviso to Section 149(1). Additionally, the notice issued on August 27, 2022, by the Joint Assessing Officer (JAO) fell outside the faceless assessment scheme u/s 151A, as it was not issued by the National Faceless Assessment Centre as required under the scheme. Consequently, the assessee's appeal was allowed.
The High Court held that the notice u/s 148 of the Income Tax Act issued on April 4, 2022, was beyond the prescribed period of limitation, rendering the consequent actions illegal. Mere issuance of a notice u/s 148A for conducting an inquiry before issuing a notice u/s 148 cannot be read within the ambit of the first proviso to Section 149(1). Additionally, the notice issued on August 27, 2022, by the Joint Assessing Officer (JAO) fell outside the faceless assessment scheme u/s 151A, as it was not issued by the National Faceless Assessment Centre as required under the scheme. Consequently, the assessee's appeal was allowed.
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