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The ITAT held that the issuance of the notice under section 148 dated 05.04.2022 by the Jurisdictional Assessing Officer (JAO) was invalid as per the CBDT Notification dated 29.03.2022, which mandates faceless assessment and automated allocation through the National Faceless Assessment Centre (NFAC) under the e-assessment scheme. The notification applies to reassessment proceedings under section 147 and requires that notices be issued only by the NFAC in accordance with the risk management strategy, thereby excluding the JAO from issuing such notices post-notification. Consequently, the impugned notice and subsequent order under section 148A(d) were quashed. The ITAT relied on High Court precedents favoring the assessee, affirming that post-notification, the JAO lacks jurisdiction to initiate reassessment proceedings in a faceless assessment regime.
The ITAT held that the issuance of the notice under section 148 dated 05.04.2022 by the Jurisdictional Assessing Officer (JAO) was invalid as per the CBDT Notification dated 29.03.2022, which mandates faceless assessment and automated allocation through the National Faceless Assessment Centre (NFAC) under the e-assessment scheme. The notification applies to reassessment proceedings under section 147 and requires that notices be issued only by the NFAC in accordance with the risk management strategy, thereby excluding the JAO from issuing such notices post-notification. Consequently, the impugned notice and subsequent order under section 148A(d) were quashed. The ITAT relied on High Court precedents favoring the assessee, affirming that post-notification, the JAO lacks jurisdiction to initiate reassessment proceedings in a faceless assessment regime.
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