Section 148 Notice Invalid in International Tax Cases if Issued by JAO Instead of FAO: Bombay HC

Shabana Aijaz Khan Vs ITO (Bombay High Court) Bombay High Court heard a writ petition challenging a reassessment notice issued under Section 148 of the Income Tax Act, 1961. The petitioner argued that the notice was invalid because it was issued by the Jurisdictional Assessing Officer (JAO) rather than the Faceless Assessing Officer, as required by law. The petitioner relied on an earlier Division Bench ruling in Hexaware Technologies Ltd. v. Assistant Commissioner of Income-tax, which held that a notice issued by a non-faceless officer was fatally defective. The petitioner argued that this pr...