Faceless reassessment under the e-Assessment of Income Escaping...

Faceless reassessment under the e-Assessment of Income Escaping Assessment Scheme, 2022 requires automated allocation for notices and all connected reassessment proceedings. Pre-notice enquiry and orders are inseparable from notice issuance and reassessment; concurrent-jurisdiction notifications cannot preserve a Jurisdictional Assessing Officer's authority where automated allocation was not used. Proceedings initiated under sections 148A and 148 by such officers were therefore set aside. Retrospective validating legislation must cure the statutory defect underlying prior judicial decisions and cannot merely override them; section 147A was unconstitutional because it left section 151A and the Scheme unchanged. Its insertion after repeal of the Income-tax Act, 1961 was also unsustainable, since specified commencement and saving provisions did not authorise amendment of a repealed enactment.