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The High Court held that for a valid reassessment notice u/s 148 of the Income Tax Act, the Revenue must comply with Section 151A, which mandates the issuance of such notice by a Faceless Assessment Officer (FAO) and not the Jurisdictional Assessing Officer (JAO). The Court reiterated that the JAO lacks jurisdiction to issue a notice u/s 148, as it would violate Section 151A's provisions. The Court emphasized that there is no concurrent jurisdiction between the JAO and FAO regarding Section 148 notices, assessments, or reassessments. Accepting concurrent jurisdiction would create chaos and render the faceless assessment proceedings redundant. Consequently, the High Court allowed the writ petition, ruling that the JAO lacked jurisdiction to issue the impugned reassessment notice.
The High Court held that for a valid reassessment notice u/s 148 of the Income Tax Act, the Revenue must comply with Section 151A, which mandates the issuance of such notice by a Faceless Assessment Officer (FAO) and not the Jurisdictional Assessing Officer (JAO). The Court reiterated that the JAO lacks jurisdiction to issue a notice u/s 148, as it would violate Section 151A's provisions. The Court emphasized that there is no concurrent jurisdiction between the JAO and FAO regarding Section 148 notices, assessments, or reassessments. Accepting concurrent jurisdiction would create chaos and render the faceless assessment proceedings redundant. Consequently, the High Court allowed the writ petition, ruling that the JAO lacked jurisdiction to issue the impugned reassessment notice.
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