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The HC held that, pursuant to the Finance Act, 2021 effective 01.04.2021, all assessment and reassessment proceedings under Section 148 must be conducted exclusively through an automated faceless mechanism, including cases assigned to central charges. Notices issued by the JAO or FAO outside this faceless scheme are invalid. The court reaffirmed the binding precedent that no exceptions exist permitting issuance of notices by JAO post-amendment, emphasizing adherence to Section 151A and Section 153D requirements. Consequently, the impugned reassessment orders issued by JAO were quashed as violative of the statutory framework introduced by the Finance Act, 2021. The question of law regarding the mode of issuance of reassessment notices in central charge cases was answered against the Revenue, affirming that such notices must be issued facelessly, thereby upholding procedural compliance and statutory mandates.
The HC held that, pursuant to the Finance Act, 2021 effective 01.04.2021, all assessment and reassessment proceedings under Section 148 must be conducted exclusively through an automated faceless mechanism, including cases assigned to central charges. Notices issued by the JAO or FAO outside this faceless scheme are invalid. The court reaffirmed the binding precedent that no exceptions exist permitting issuance of notices by JAO post-amendment, emphasizing adherence to Section 151A and Section 153D requirements. Consequently, the impugned reassessment orders issued by JAO were quashed as violative of the statutory framework introduced by the Finance Act, 2021. The question of law regarding the mode of issuance of reassessment notices in central charge cases was answered against the Revenue, affirming that such notices must be issued facelessly, thereby upholding procedural compliance and statutory mandates.
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