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The HC held that notices and orders issued outside the faceless assessment mechanism under Section 144(b) read with Section 151A and the E-Assessment Scheme, 2022 are void for jurisdictional infirmity. Applying precedent from superior fora, the Court concluded the JAO lacked jurisdiction to issue the impugned communications where the Scheme and statutory mandate required issuance through the faceless/FAO process; consequently the reassessment proceedings initiated pursuant thereto are quashed. Relief granted to the assessee: all impugned notices and consequential orders issued by the JAO or otherwise outside the prescribed faceless mechanism are declared bad in law and set aside.
The HC held that notices and orders issued outside the faceless assessment mechanism under Section 144(b) read with Section 151A and the E-Assessment Scheme, 2022 are void for jurisdictional infirmity. Applying precedent from superior fora, the Court concluded the JAO lacked jurisdiction to issue the impugned communications where the Scheme and statutory mandate required issuance through the faceless/FAO process; consequently the reassessment proceedings initiated pursuant thereto are quashed. Relief granted to the assessee: all impugned notices and consequential orders issued by the JAO or otherwise outside the prescribed faceless mechanism are declared bad in law and set aside.
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