Notices issued by Jurisdictional Assessing Officer (JAO) u/s 148 instead of Faceless Assessment Officer...

Notices issued by Jurisdictional Assessing Officer (JAO) u/s 148 instead of Faceless Assessment Officer (FAO) are invalid after introduction of Finance Act 2021. Scheme of faceless assessment applies from notice stage u/ss 148 and 148A as per notification u/s 151A. Assessment proceedings commence from issuance of show cause notice. Allowing JAO to issue notice would defeat faceless assessment objective. Departmental circulars cannot override statutory provisions; courts are not bound by them. Circulars supplement but cannot supplant statutory provisions. Notices issued by JAO u/s 148 quashed; liberty granted to proceed as per prescribed procedure. .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X