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Reassessment proceedings were held invalid because, prior to issuance of the order under section 148A(d) and notice under section 148 dated 31.03.2022 by the jurisdictional AO, the Central Government had notified the faceless scheme under section 151A mandating that actions under sections 148A(b), 148A(d) and issuance of notice under section 148 be undertaken only through the faceless mechanism. Since the notice was issued contrary to this statutory mandate, the non-compliance was treated as violative of the rule of law, rendering the notice unsustainable; consequently, the reassessment order passed under section 147 read with section 144 was quashed and the appeal was allowed. - ITAT
Reassessment proceedings were held invalid because, prior to issuance of the order under section 148A(d) and notice under section 148 dated 31.03.2022 by the jurisdictional AO, the Central Government had notified the faceless scheme under section 151A mandating that actions under sections 148A(b), 148A(d) and issuance of notice under section 148 be undertaken only through the faceless mechanism. Since the notice was issued contrary to this statutory mandate, the non-compliance was treated as violative of the rule of law, rendering the notice unsustainable; consequently, the reassessment order passed under section 147 read with section 144 was quashed and the appeal was allowed. - ITAT
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