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ITAT held that notices issued under section 148 and section 148A(b) by the jurisdictional assessing officer, instead of the faceless assessing officer, are invalid and set aside; consequent reassessment orders premised on such notices are quashed. The Tribunal further determined that where the assessing officer, in reassessment proceedings, made no addition on the very issue forming the basis for reopening, the officer lacked jurisdiction to make other additions, rendering the reassessment void. Parties were granted liberty to seek revival of the appeal should controlling decisions of higher courts on the faceless-notice issue necessitate modification of this order.
ITAT held that notices issued under section 148 and section 148A(b) by the jurisdictional assessing officer, instead of the faceless assessing officer, are invalid and set aside; consequent reassessment orders premised on such notices are quashed. The Tribunal further determined that where the assessing officer, in reassessment proceedings, made no addition on the very issue forming the basis for reopening, the officer lacked jurisdiction to make other additions, rendering the reassessment void. Parties were granted liberty to seek revival of the appeal should controlling decisions of higher courts on the faceless-notice issue necessitate modification of this order.
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