Manual Section 148 Notices Violate CBDT Escaping Assessment Scheme

Vivek Kumarasamy Vs ITO (ITAT Chennai) JAO-Issued Notice- Faceless Breach Invalidates 148 Notice—Subject to Revival if Apex Court Overturns Hexaware Line Assessee filed appeal with a delay of 73 days which Tribunal condoned. Assessee raised an additional legal ground that the notice u/s 148 dated 31.03.2023 issued by ITO, Ward 2(1), Erode (JAO) is without jurisdiction since CBDT Notification dated 29.03.2022 mandates that issuance of notice u/s 148 & reassessment u/s 147 shall be through automated allocation in a faceless manner by NFAC. Tribunal noted that the impugned notice was manual...