https://www.taxtmi.com/caselaws?id=465168 A notice under Section 148 issued by the jurisdictional Assessing Officer was considered challengeable for lack of jurisdiction because the faceless assessment regime was treated as applying from the notice stage itself. The analysis applied the CBDT notification dated 29.03.2022 and Section 151A to conclude that issuance of the notice falls within the faceless mechanism, and that assessment proceedings begin with the show-cause notice stage. It also reaffirmed that administrative instructions or circulars cannot override the statutory mandate. en-us Thu, 07 Aug 2025 00:00:00 +0530 Mon, 08 Dec 2025 18:58:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465168 A notice under Section 148 issued by the jurisdictional Assessing Officer was considered challengeable for lack of jurisdiction because the faceless assessment regime was treated as applying from the notice stage itself. The analysis applied the CBDT notification dated 29.03.2022 and Section 151A to conclude that issuance of the notice falls within the faceless mechanism, and that assessment proceedings begin with the show-cause notice stage. It also reaffirmed that administrative instructions or circulars cannot override the statutory mandate. Case-Laws Income Tax Thu, 07 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465168