Section 148 Notice by JAO After Faceless Regime? Chennai ITAT Quashes Both Reassessments

Arulmigu Vettudaiyar Kaliamman Thirukovil Vs ITO (ITAT Chennai) Assessee challenged reassessment solely on the legal ground that notices u/s 148 dated 31.03.2022 (AY 2015-16) & 29.03.2023 (AY 2016-17) were issued by the Jurisdictional AO (JAO) instead of the Faceless Unit, contrary to Sec.151A & CBDT’s Faceless Reassessment Scheme notified on 29.03.2022, which mandates automated/faceless issuance of all 148/148A notices post-notification. Tribunal examined the notices, &  relied on the Madras High Court Division Bench in Mark Studio India Pvt Ltd (24.06.2025) which expressly rev...