https://www.taxtmi.com/highlights?id=79934 Reopening of assessment u/s 147 - Validity of approval u/s 151 - notice not issued by Faceless Assessing Officer (FAO) - There is no concurrent jurisdiction for Joint Assessing Officer (JAO) and FAO for issuing notice u/s 148 or passing assessment/reassessment order. When specific jurisdiction assigned to FAO under Scheme dated 29 March 2022 notified u/s 151A, it excludes JAO's jurisdiction. Section 151A contemplates formulation of Scheme for assessment/reassessment u/s 147 and issuance of notice u/s 148. Scheme covers both aspects. Only FAO can issue notice u/s 148, not JAO. Impugned notice issued by JAO hit by Section 151A for lack of jurisdiction. Impugned notice u/s 148 quashed and set aside as barred by limitation and contrary to Section 151A. en-us Wed, 31 Jul 2024 08:37:09 +0530 Wed, 31 Jul 2024 08:37:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=79934 Reopening of assessment u/s 147 - Validity of approval u/s 151 - notice not issued by Faceless Assessing Officer (FAO) - There is no concurrent jurisdiction for Joint Assessing Officer (JAO) and FAO for issuing notice u/s 148 or passing assessment/reassessment order. When specific jurisdiction assigned to FAO under Scheme dated 29 March 2022 notified u/s 151A, it excludes JAO's jurisdiction. Section 151A contemplates formulation of Scheme for assessment/reassessment u/s 147 and issuance of notice u/s 148. Scheme covers both aspects. Only FAO can issue notice u/s 148, not JAO. Impugned notice issued by JAO hit by Section 151A for lack of jurisdiction. Impugned notice u/s 148 quashed and set aside as barred by limitation and contrary to Section 151A. Highlights Income Tax Wed, 31 Jul 2024 08:37:09 +0530 https://www.taxtmi.com/highlights?id=79934