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The High Court held that the order passed by the National Faceless Assessment Centre (NFAC) u/ss 143(3)/254/144B of the Income Tax Act was invalid as it lacked jurisdiction. The Revenue failed to file a counter-affidavit despite being granted multiple opportunities. The Court accepted the petitioner's uncontested facts that the assessment proceedings had concluded with the order dated 04.02.2023, giving effect to the Income Tax Appellate Tribunal's directions. Initiating further proceedings by the NFAC after passing the assessment order was without jurisdiction, as concluded assessments cannot be reopened except through specific statutory provisions like Section 147 of the Act.
The High Court held that the order passed by the National Faceless Assessment Centre (NFAC) u/ss 143(3)/254/144B of the Income Tax Act was invalid as it lacked jurisdiction. The Revenue failed to file a counter-affidavit despite being granted multiple opportunities. The Court accepted the petitioner's uncontested facts that the assessment proceedings had concluded with the order dated 04.02.2023, giving effect to the Income Tax Appellate Tribunal's directions. Initiating further proceedings by the NFAC after passing the assessment order was without jurisdiction, as concluded assessments cannot be reopened except through specific statutory provisions like Section 147 of the Act.
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