Parankusam Sri Perumundhur Gopalakrishnan Vs PCIT (Madras High Court)
Madras High Court Sets Aside Reassessment Notice Issued by Jurisdictional Assessing Officer (JAO) — Upholds Mandatory Faceless Regime
Appellant challenged the order of a Single Judge dated 09.07.2025 which had upheld the reassessment proceedings initiated by the Jurisdictional Assessing Officer (JAO). Appellant contended that the notice dated 05.03.2025 issued by the JAO for reopening the assessment was void ab initio, since under the current Faceless Assessment & Reassessment Scheme, all such proceedings must be initiated only by the Faceless Assessment Officer (FAO) and not by the local jurisdictional officer.
Appellant’s Argument
Appellant relied heavily on the Division Bench decision of the Madras High Court in TVS Credit Services Ltd. vs. DCIT & Ors. (W.P. No. 22402 of 2024, batch, dated 24.06.2025), wherein it was categorically held that:
“Issuance of notice by the Jurisdictional AO instead of the Faceless AO is without jurisdiction and renders the entire proceeding invalid.”
He also referred to similar decisions in Vijay vs. ITO (batch) delivered on the same day, reinforcing that all reassessment actions post-faceless regime must emanate only from the FAO.
Revenue’s Stand
The Revenue sought additional time to file a response but did not dispute the existence of the earlier binding Division Bench rulings.
