Tax Assessment Notice Validity: Faceless Regime Violation Renders Reopening Invalid.

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....Validity of reopening income tax assessment proceedings. The key points are: the Jurisdictional Assessing Officer (JAO) issued the notice for reopening assessment instead of a Faceless Assessing Officer (FAO), violating the statutory scheme u/s 151A(2) of the Income Tax Act. The court held that non-compliance with the faceless assessment scheme, which has the character of subordinate legislation, renders the initiation of proceedings invalid. Both parties agreed that the reopening proceedings would be unsustainable due to the Hexaware judgment. Since the JAO lacked jurisdiction to issue the notice and the issue was time-barred, the writ petition was allowed.....