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Reopening of assessment u/s 147 - Validity of approval u/s 151 - notice not issued by Faceless Assessing Officer (FAO) - There is no concurrent jurisdiction for Joint Assessing Officer (JAO) and FAO for issuing notice u/s 148 or passing assessment/reassessment order. When specific jurisdiction assigned to FAO under Scheme dated 29 March 2022 notified u/s 151A, it excludes JAO's jurisdiction. Section 151A contemplates formulation of Scheme for assessment/reassessment u/s 147 and issuance of notice u/s 148. Scheme covers both aspects. Only FAO can issue notice u/s 148, not JAO. Impugned notice issued by JAO hit by Section 151A for lack of jurisdiction. Impugned notice u/s 148 quashed and set aside as barred by limitation and contrary to Section 151A.
Reopening of assessment u/s 147 - Validity of approval u/s 151 - notice not issued by Faceless Assessing Officer (FAO) - There is no concurrent jurisdiction for Joint Assessing Officer (JAO) and FAO for issuing notice u/s 148 or passing assessment/reassessment order. When specific jurisdiction assigned to FAO under Scheme dated 29 March 2022 notified u/s 151A, it excludes JAO's jurisdiction. Section 151A contemplates formulation of Scheme for assessment/reassessment u/s 147 and issuance of notice u/s 148. Scheme covers both aspects. Only FAO can issue notice u/s 148, not JAO. Impugned notice issued by JAO hit by Section 151A for lack of jurisdiction. Impugned notice u/s 148 quashed and set aside as barred by limitation and contrary to Section 151A.
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