https://www.taxtmi.com/highlights?id=104754 Section 151A and the e-Assessment of Income Escaping Assessment Scheme, 2022 require randomised automated allocation for reassessment functions, including the section 148A process and issuance of section 148 notices. General concurrent-jurisdiction directions cannot permit a jurisdictional Assessing Officer to bypass the prescribed faceless allocation, because allocation determines the officer's statutory competence. Risk-based selection of a matter is distinct from algorithmic allocation of the officer. Section 147A's retrospective deeming rule was held unconstitutional because it did not amend the continuing statutory and scheme-based requirements for automated allocation, and therefore did not remove the legal foundation of prior jurisdictional rulings. Administrative instructions cannot override the Act or a valid notified scheme. en-us Fri, 09 Oct 2026 11:53:18 +0530 Fri, 09 Oct 2026 11:53:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104754 Section 151A and the e-Assessment of Income Escaping Assessment Scheme, 2022 require randomised automated allocation for reassessment functions, including the section 148A process and issuance of section 148 notices. General concurrent-jurisdiction directions cannot permit a jurisdictional Assessing Officer to bypass the prescribed faceless allocation, because allocation determines the officer's statutory competence. Risk-based selection of a matter is distinct from algorithmic allocation of the officer. Section 147A's retrospective deeming rule was held unconstitutional because it did not amend the continuing statutory and scheme-based requirements for automated allocation, and therefore did not remove the legal foundation of prior jurisdictional rulings. Administrative instructions cannot override the Act or a valid notified scheme. Highlights Income Tax Fri, 09 Oct 2026 11:53:18 +0530 https://www.taxtmi.com/highlights?id=104754