Faceless reassessment jurisdiction: initiation remains with the Jurisdictional Assessing Officer after statutory clarification of authority
The central legal issue is whether initiation of reassessment must occur through automated faceless allocation or may be undertaken by the Jurisdictional Assessing Officer. Courts are divided between treating the faceless scheme as a jurisdictional condition precedent, invalidating non-compliant proceedings, and viewing it as procedural, permitting concurrent initiation by the Jurisdictional Assessing Officer. Recent legislative deeming clarification purports to designate the Jurisdictional Assessing Officer as the competent authority to issue reassessment notices, but its retrospective effect will shape ongoing litigation. (AI Summary)