Faceless Tax Assessment Ruling: Notices Must Follow Automated Process to Ensure Fairness, No Manual Requests Allowed.

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....The High Court addressed the issue of faceless assessment of income escaping assessment u/s 151A scheme. It held that notices must be issued in a faceless manner as mandated, without physical interface. The scheme allows for automated allocation and issuance of notices u/s 148 in a faceless manner. The statute aims to prevent prejudice and bias by automated allocation through risk management strategy. The Court cited judgments supporting automated issuance of notices without any interface. The Court clarified that there is no fundamental right for an assessee to demand manual issuance of notices. The Department must adhere to the scheme for assessment, re-assessment, and issuance of notices. If the Department withdraws notices, fresh notices may be issued following the scheme and u/s 151A, allowing the petitioner to respond under Section 148.....