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The High Court held that the provisions of Section 144B read with Section 151A, which mandate a faceless assessment mechanism, are applicable to cases involving central charges and international taxation charges. The faceless mechanism applies to proceedings u/ss 148A and 148 of the Income Tax Act, relating to the issuance of notices for reassessment. The Court rejected the revenue's contention that the present case falls outside the applicability of these provisions and the scheme notified by the Central Government on March 29, 2022. The notices issued by the Joint Assessing Officer (JAO) were held to be illegal and without jurisdiction as they fell outside the purview of the faceless mechanism. The Court relied on its earlier decisions in Hexaware, CapitalG LP, and Sri Venkataramana Reddy Patloola, which consistently held that central charges and international taxation charges are subject to the faceless assessment mechanism u/ss 144B and 151A, including proceedings u/ss 148A and 148. The decision was in favor of the assessee.
The High Court held that the provisions of Section 144B read with Section 151A, which mandate a faceless assessment mechanism, are applicable to cases involving central charges and international taxation charges. The faceless mechanism applies to proceedings u/ss 148A and 148 of the Income Tax Act, relating to the issuance of notices for reassessment. The Court rejected the revenue's contention that the present case falls outside the applicability of these provisions and the scheme notified by the Central Government on March 29, 2022. The notices issued by the Joint Assessing Officer (JAO) were held to be illegal and without jurisdiction as they fell outside the purview of the faceless mechanism. The Court relied on its earlier decisions in Hexaware, CapitalG LP, and Sri Venkataramana Reddy Patloola, which consistently held that central charges and international taxation charges are subject to the faceless assessment mechanism u/ss 144B and 151A, including proceedings u/ss 148A and 148. The decision was in favor of the assessee.
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