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The HC quashed reassessment notices issued by Jurisdictional Assessing Officers (JAOs), ruling they lacked jurisdiction under Section 151A of the Income Tax Act. The court held that Faceless Assessing Officers (FAOs) have exclusive jurisdiction for notices under Sections 147 and 148, as mandated by the CBDT Notification dated 29.03.2022. The court emphasized that concurrent jurisdiction between JAOs and FAOs would defeat the statutory purpose of Sections 151A and 144B. The algorithmic random allocation system must be strictly followed to maintain the integrity of the faceless assessment regime. Liberty was granted to respondents to issue fresh notices through proper FAO channels in compliance with the notification.
The HC quashed reassessment notices issued by Jurisdictional Assessing Officers (JAOs), ruling they lacked jurisdiction under Section 151A of the Income Tax Act. The court held that Faceless Assessing Officers (FAOs) have exclusive jurisdiction for notices under Sections 147 and 148, as mandated by the CBDT Notification dated 29.03.2022. The court emphasized that concurrent jurisdiction between JAOs and FAOs would defeat the statutory purpose of Sections 151A and 144B. The algorithmic random allocation system must be strictly followed to maintain the integrity of the faceless assessment regime. Liberty was granted to respondents to issue fresh notices through proper FAO channels in compliance with the notification.
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