2026 (8) TMI 290

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....f of the Revenue Department has also been heard. The instant Review Application has been filed seeking review of the judgment and order dated 26.09.2023 passed in Writ Tax No. 1076 of 2023, whereby and whereunder the Writ Tax was dismissed. The judgment and order dated 26.09.2023 was carried in SLP being SLP (C) No. 4224 of 2024 primarily on the ground that the Review Applicant/ Petitioner had specifically urged the ground of non-compliance of the procedure under Section 151-A of the Income Tax Act having been taken before this Court in the Writ Petition but the same was not considered. The Apex Court found that in fact there was no submission based on section 151-A of the Income tax Act and declined to interfere with the judgment. Howev....

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....pre-notice and notice stages under Section 148-A and 148. Jurisdictional Assessing Officers as in the case at hand issued orders under Section 148(d) and consequential notice under Section 148 without routing them through the faceless mechanism. Different High Courts gave different views. While same High Court held that the Jurisdictional Assessing Officer and the National Faceless Assessment Centre had concurrent jurisdiction and that scheme did not displace the Jurisdictional Assessing Officer, other High Courts quashed the notices and proceedings on the ground that they were not issued through the faceless mechanism thereby vitiating subsequent reassessment steps. The matter travelled to the Apex Court and the issue was pending in appeal....