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The court held that the Joint Assessing Officer (JAO) lacked jurisdiction to issue notices u/s 148 of the Income Tax Act for reassessment, as per Section 151A read with the Central Government notification dated 29 March 2022. This provision mandates that such notices be issued by the Faceless Assessment Officer (FAO). Relying on the Hexaware Technologies Ltd. case, the court concluded that the impugned notices issued by the JAO were illegal and invalid due to lack of jurisdiction. Consequently, the court allowed the petition in favor of the assessee, quashing the reassessment notices.
The court held that the Joint Assessing Officer (JAO) lacked jurisdiction to issue notices u/s 148 of the Income Tax Act for reassessment, as per Section 151A read with the Central Government notification dated 29 March 2022. This provision mandates that such notices be issued by the Faceless Assessment Officer (FAO). Relying on the Hexaware Technologies Ltd. case, the court concluded that the impugned notices issued by the JAO were illegal and invalid due to lack of jurisdiction. Consequently, the court allowed the petition in favor of the assessee, quashing the reassessment notices.
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