https://www.taxtmi.com/caselaws?id=801094 Retrospective validation of reassessment jurisdiction is constitutionally sustainable only when legislation removes the statutory defect underlying earlier jurisdictional rulings; it cannot merely override those rulings while the governing faceless scheme remains unchanged. Section 151A and the 2022 Scheme require automated allocation and faceless reassessment, including the interlinked pre-notice process under section 148A and notice under section 148, leaving Jurisdictional Assessing Officers without authority to initiate proceedings outside that mechanism. Concurrent-jurisdiction notifications and non-compliant transfer to the National Faceless Assessment Centre do not cure that defect. An amendment expressly commencing after repeal cannot be inserted into the repealed Income-tax Act, 1961. en-us Mon, 12 Oct 2026 00:00:00 +0530 Thu, 15 Oct 2026 05:44:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801094 Retrospective validation of reassessment jurisdiction is constitutionally sustainable only when legislation removes the statutory defect underlying earlier jurisdictional rulings; it cannot merely override those rulings while the governing faceless scheme remains unchanged. Section 151A and the 2022 Scheme require automated allocation and faceless reassessment, including the interlinked pre-notice process under section 148A and notice under section 148, leaving Jurisdictional Assessing Officers without authority to initiate proceedings outside that mechanism. Concurrent-jurisdiction notifications and non-compliant transfer to the National Faceless Assessment Centre do not cure that defect. An amendment expressly commencing after repeal cannot be inserted into the repealed Income-tax Act, 1961. Case-Laws Income Tax Mon, 12 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801094