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The ITAT held that post the CBDT notification dated 29.03.2022, notices under section 148 must be issued exclusively by faceless assessing officers. Any notice issued by a jurisdictional assessing officer after this date is invalid. In the present case, the section 148 notice dated 30.03.2022 was issued by the jurisdictional officer, rendering it void ab initio. Consequently, the assessment order under section 147 dated 16.03.2023, based on the invalid notice, was also set aside. The tribunal quashed the notice and allowed the assessee's appeal, affirming that the procedural mandate for faceless issuance is mandatory and non-compliance vitiates the assessment proceedings.
The ITAT held that post the CBDT notification dated 29.03.2022, notices under section 148 must be issued exclusively by faceless assessing officers. Any notice issued by a jurisdictional assessing officer after this date is invalid. In the present case, the section 148 notice dated 30.03.2022 was issued by the jurisdictional officer, rendering it void ab initio. Consequently, the assessment order under section 147 dated 16.03.2023, based on the invalid notice, was also set aside. The tribunal quashed the notice and allowed the assessee's appeal, affirming that the procedural mandate for faceless issuance is mandatory and non-compliance vitiates the assessment proceedings.
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