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<h1>Faceless assessment procedure must govern issuance of Section 148 notices in international tax matters, irrespective of residency.</h1> The court held that the plain language of the faceless scheme, Section 144B(2) and the CBDT order requires that issuance of Section 148 notices in matters involving international tax charges comply with the mandatory faceless assessment procedure, irrespective of the taxpayer's residency status, and that notices issued without adherence to that procedure are inconsistent with the statutory scheme.
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