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The HC set aside proceedings initiated under sections 148A and 148, holding the notices invalid because they were not issued through the statutorily mandated faceless mechanism introduced by the Finance Act, 2021 and Notification dated 29.03.2022 read with section 151A; the issuance by the territorial AO rendered the reassessment jurisdictionally infirm. Writ petitions by the assessee were allowed, the reassessment proceedings quashed, and consequential reliefs granted. The court noted its prior ruling on the same legal question and observed that subsequent benches in several HCs have reached the same conclusion, uniformly deciding against the revenue on the faceless-notice compliance issue.
The HC set aside proceedings initiated under sections 148A and 148, holding the notices invalid because they were not issued through the statutorily mandated faceless mechanism introduced by the Finance Act, 2021 and Notification dated 29.03.2022 read with section 151A; the issuance by the territorial AO rendered the reassessment jurisdictionally infirm. Writ petitions by the assessee were allowed, the reassessment proceedings quashed, and consequential reliefs granted. The court noted its prior ruling on the same legal question and observed that subsequent benches in several HCs have reached the same conclusion, uniformly deciding against the revenue on the faceless-notice compliance issue.
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