2026 (10) TMI 427

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....R. JUSTICE SUNISH BINDLISH Ms. Gauri Neo Rampal, Sr. Standing counsel (through VC) for the appellant. For the Respondent : None ORDER DEEPAK SIBAL, J. (Oral) 1. Through this appeal, the revenue raises the following substantial questions of law:- "(a) Whether the Hon'ble ITAT has misinterpreted the term 'Faceless Manner' in Assessment of Income Escaping Assessmen....

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....t' procedure whose application is advent upon filing of return of income upon notice under Section 148 as provided in sub-section (1)(iii)(b) of Section 144B w.r.t. issuance of notice of Section 148 by Faceless Assessing Officer (FAO)? (d) Whether the Hon'ble ITAT has taken into the consideration the automatic allocation of Assessee to the Jurisdictional Assessing Officers in acco....

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....e notice issued under Section 148 by the Jurisdictional Assessing Officer JAO), failed to appreciate that the same is consistent with the legislative intent. when the powers to issue the notice under Section 148 remained intact with the JAO even after bringing the 'Faceless Assessment Scheme? (g) Whether on the facts and circumstances of the case and in law, the Hon'ble ITAT is co....

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....ion 148 by the JAO as per automated management allocation and risk strategies as per provisions of Section 151A read with Section 144B of the Income Tax Act? (j) Whether the Hon'ble ITAT is correct in law in holding that the Section 144B, 151A of the Income Act, r/w CBDT Notification No.18/2022 dated 29.03.2022 mandate that the notice under Section 148 shall only by Faceless, when the....