Reopening Collapses: 148 Notice by Jurisdictional AO After 29.03.2022 Held Void ab initio

Siva Kumar Dhanapal Vs ITO (ITAT Chennai)

In this appeal, Assessee challenged the validity of notice issued u/s 148 dated 31.03.2024 by JAO, contending that after notification of Faceless Reassessment Scheme u/s 151A on 29.03.2022, issuance of notice u/s 148A(b)/148 must be only through NFAC by automated allocation. Since the notice was manually issued by JAO, Assessee argued that entire reopening is void ab initio. Assessee relied on binding jurisdictional Madras HC Division Bench ruling in Mark Studio India (P.) Ltd (24.06.2025) which fol

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