Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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ITAT held the reassessment proceedings invalid on the ground that the notice issued under s.148 by the Jurisdictional Assessing Officer (JAO) after the relevant CBDT notification was without legal authority under the faceless assessment scheme. Following the binding ruling of the Telangana HC, ITAT quashed the impugned s.148 notice dated 07.04.2022 and, consequentially, the reassessment framed thereunder. ITAT noted that the issue is pending before the SC in a Revenue SLP concerning similar legal questions and recorded that the parties are at liberty to seek revival and modification of this order depending on the SC's final decision. The assessee's appeal was accordingly allowed, with liberty as stated.
ITAT held the reassessment proceedings invalid on the ground that the notice issued under s.148 by the Jurisdictional Assessing Officer (JAO) after the relevant CBDT notification was without legal authority under the faceless assessment scheme. Following the binding ruling of the Telangana HC, ITAT quashed the impugned s.148 notice dated 07.04.2022 and, consequentially, the reassessment framed thereunder. ITAT noted that the issue is pending before the SC in a Revenue SLP concerning similar legal questions and recorded that the parties are at liberty to seek revival and modification of this order depending on the SC's final decision. The assessee's appeal was accordingly allowed, with liberty as stated.
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