Faceless Assessment Regime Limits Authority of Jurisdictional Assessing Officers in Issuing Section 148 Notices.

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....The High Court held that the Jurisdictional Assessing Officer (JAO) is not permitted to issue a notice u/s 148 of the Income Tax Act, as it would violate the provisions of Section 151A, which mandates faceless assessment. The Court relied on recent decisions in Nainraj Enterprises Pvt. Ltd. and Hexaware Technology Ltd., where it was established that the faceless assessment regime u/s 151A excludes the JAO's jurisdiction to issue notices u/s 148. The Court clarified that there is no concurrent jurisdiction between the JAO and the Faceless Assessment Officer (FAO) for issuing notices u/s 148 or passing assessment/reassessment orders. When specific jurisdiction is assigned to either the JAO or the FAO under the Faceless Assessment Scheme, it i.........