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The High Court held that the notice issued by the Jurisdictional Assessing Officer (JAO) u/s 148 was invalid as the provisions of Section 151A mandate that such notice must be issued by a Faceless Assessing Officer (FAO). The Revenue failed to comply with the Scheme notified by the Central Government pursuant to Section 151A(2), which governs the conduct of proceedings u/ss 148A and 148. Relying on the Hexaware case, the court concluded that the invalid issuance of notice vitiated the entire proceedings initiated against the assessee.