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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.
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.
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