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The High Court ruled that the Joint Assistant Commissioner (JAO) lacked jurisdiction to issue notices u/s 148 for reassessment of income escaping assessment. The notices were deemed illegal and invalid due to non-compliance with Section 151A, which mandates such notices to be issued by the Faceless Assessment Officer (FAO) as per the Central Government's notification dated March 29, 2022. The Court concurred with its previous decision in Hexaware Technologies Ltd., acknowledging the JAO's lack of authority in issuing the impugned notices. Consequently, the petition was allowed in favor of the assessee, nullifying the notices issued by the JAO.
The High Court ruled that the Joint Assistant Commissioner (JAO) lacked jurisdiction to issue notices u/s 148 for reassessment of income escaping assessment. The notices were deemed illegal and invalid due to non-compliance with Section 151A, which mandates such notices to be issued by the Faceless Assessment Officer (FAO) as per the Central Government's notification dated March 29, 2022. The Court concurred with its previous decision in Hexaware Technologies Ltd., acknowledging the JAO's lack of authority in issuing the impugned notices. Consequently, the petition was allowed in favor of the assessee, nullifying the notices issued by the JAO.
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