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HC held that notices under s.148 issued by jurisdictional Assessing Officer remain valid despite faceless assessment requirements, as traditional and faceless mechanisms are meant to work complementarily. The Court rejected challenges to AO's jurisdiction, clarifying that distribution of functions between jurisdictional AO and National Faceless Assessment Centre is concurrent. However, approvals granted by Joint Commissioner post April 1, 2021, were deemed invalid. AOs were directed to evaluate individual show cause notices considering precedents from T.K.S. Builders, Abhinav Jindal, and Naveen Kumar Gupta cases regarding sanction under s.151 and reassessment procedures. Assessment of limitation periods must follow Rajeev Bansal and Ram Balram judgments. AOs must issue reasoned orders determining validity of reassessment notices, with petitioners retaining right to challenge adverse decisions.
HC held that notices under s.148 issued by jurisdictional Assessing Officer remain valid despite faceless assessment requirements, as traditional and faceless mechanisms are meant to work complementarily. The Court rejected challenges to AO's jurisdiction, clarifying that distribution of functions between jurisdictional AO and National Faceless Assessment Centre is concurrent. However, approvals granted by Joint Commissioner post April 1, 2021, were deemed invalid. AOs were directed to evaluate individual show cause notices considering precedents from T.K.S. Builders, Abhinav Jindal, and Naveen Kumar Gupta cases regarding sanction under s.151 and reassessment procedures. Assessment of limitation periods must follow Rajeev Bansal and Ram Balram judgments. AOs must issue reasoned orders determining validity of reassessment notices, with petitioners retaining right to challenge adverse decisions.
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