Reopening Quashed- JAO’s 148 After 29.03.2022 Invalid – Faceless Scheme is Mandatory

Nazia Amreen Vs ITO (ITAT Chennai) Assessee challenged validity of notice u/s 148 dated 31.03.2022 issued by JAO, contending that after CBDT notification dated 29.03.2022 framing the “e-Assessment of Income Escaping Assessment Scheme, 2022” u/s 151A, issuance of all notices u/s 148A(b), 148A(d) & 148 must be through automated faceless allocation via NFAC. Since JAO issued the notice manually, Assessee argued reopening is void ab initio. Reliance was placed on Madras HC Division Bench ruling in Mark Studio India (P.) Ltd (24.06.2025), which followed Hexaware Technologies (Bom HC), holdi...