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HC quashed reassessment notices issued under Sections 148A and 148, holding they violated faceless assessment provisions mandated by Finance Act 2021. The jurisdictional Assessing Officer improperly issued notices that should have been processed through faceless mechanism per Section 151A read with Notification 18/2022. HC followed its precedent in Petitioner A v. ITO, which established such proceedings as invalid for non-compliance with faceless requirements. Despite Revenue's continuous issuance of similar notices across jurisdictions for sixteen months post-judgment, HC disposed matter as covered by established precedent. However, relief granted subject to outcome of pending SLP before SC challenging the precedent judgment, allowing either party to seek revival based on SC's final determination.
HC quashed reassessment notices issued under Sections 148A and 148, holding they violated faceless assessment provisions mandated by Finance Act 2021. The jurisdictional Assessing Officer improperly issued notices that should have been processed through faceless mechanism per Section 151A read with Notification 18/2022. HC followed its precedent in Petitioner A v. ITO, which established such proceedings as invalid for non-compliance with faceless requirements. Despite Revenue's continuous issuance of similar notices across jurisdictions for sixteen months post-judgment, HC disposed matter as covered by established precedent. However, relief granted subject to outcome of pending SLP before SC challenging the precedent judgment, allowing either party to seek revival based on SC's final determination.
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