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of <h1>Faceless reassessment doesn't eliminate JAOs' role; two-stage process under Sections 148A, 148 and 144B preserves remedies</h1> The court held that the faceless reassessment framework does not wholly oust the jurisdiction of jurisdictional assessing officers (JAOs); a two-stage model prevails whereby RMS/Insight Portal outputs may be acted on by JAOs for pre-notice inquiries under section 148A and, if satisfaction is formed, the JAO may issue a section 148 notice, with NFAC thereafter conducting faceless assessment under section 144B. Deletion of the former automatic nullity provision counsels against treating procedural non-compliance as voidity; procedural lapses are reviewable but do not automatically invalidate reassessments. Assessees retain remedies to challenge lack of information, mala fides, or other procedural defects.
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