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ITAT allowed the assessee's appeal, holding the reassessment proceedings invalid. It found that, pursuant to the CBDT Notification dated 29.03.2022 framing the E-Assessment of Income Assessment Scheme, 2022, issuance of notice under s.148 must be through automated allocation and in a faceless manner by the designated faceless authority, not by the jurisdictional assessing officer. As the impugned notice under s.148, dated 28.03.2024, was issued by the local JAO and not by NFAC, it was held contrary to the Scheme and ultra vires. Consequently, the s.147 proceedings and ensuing assessment stood vitiated and were quashed.
ITAT allowed the assessee's appeal, holding the reassessment proceedings invalid. It found that, pursuant to the CBDT Notification dated 29.03.2022 framing the E-Assessment of Income Assessment Scheme, 2022, issuance of notice under s.148 must be through automated allocation and in a faceless manner by the designated faceless authority, not by the jurisdictional assessing officer. As the impugned notice under s.148, dated 28.03.2024, was issued by the local JAO and not by NFAC, it was held contrary to the Scheme and ultra vires. Consequently, the s.147 proceedings and ensuing assessment stood vitiated and were quashed.
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