2025 (6) TMI 1412

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....dv. Dharan Gandhi,. For the Respondent: Adv. Subir Kumar a/w Adv. Niyanta Trivedi,. P. C. 1. The above Writ Petition takes exception to the notice issued by the Revenue dated 29th March 2025 under Section 148 of the Income Tax Act, 1961 ("IT Act") and the approval dated 29th March 2025 issued under Section 151 thereof. 2. Though several grounds to challenge the said notice have been set out....

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....39 thereof, we find that this Court has specifically held that the notice to be issued under Section 148 would have to be as per the Scheme floated by the CBDT dated 29th March 2022 and would have to be by the Faceless Assessing Officer. This Court has specifically held that the Jurisdictional Assessing Officer would have no jurisdiction to issue the notice under Section 148. We not only agree wit....