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The High Court held that the Jurisdictional Assessing Officer (JAO) has valid jurisdiction to issue a notice u/s 148 for reopening of assessment, even in cases of search and seizure u/s 132. The faceless assessment scheme u/s 151A mandates recording satisfaction by the JAO before issuing such notice, but does not preclude the JAO from issuing the notice directly. The Court observed that the scheme aims to eliminate interface between tax authorities and assessees to the extent technologically feasible. The petitioner's challenge to the notice on grounds of lack of jurisdiction was rejected. The Court noted that satisfaction notes were provided, and subsequent proceedings like notice u/s 142(1) were issued by the Verification Unit of the Faceless Assessment Centre. The petitioners were advised to pursue remedies before the competent authority and seek virtual hearings if required, ensuring strict compliance with the law.
The High Court held that the Jurisdictional Assessing Officer (JAO) has valid jurisdiction to issue a notice u/s 148 for reopening of assessment, even in cases of search and seizure u/s 132. The faceless assessment scheme u/s 151A mandates recording satisfaction by the JAO before issuing such notice, but does not preclude the JAO from issuing the notice directly. The Court observed that the scheme aims to eliminate interface between tax authorities and assessees to the extent technologically feasible. The petitioner's challenge to the notice on grounds of lack of jurisdiction was rejected. The Court noted that satisfaction notes were provided, and subsequent proceedings like notice u/s 142(1) were issued by the Verification Unit of the Faceless Assessment Centre. The petitioners were advised to pursue remedies before the competent authority and seek virtual hearings if required, ensuring strict compliance with the law.
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