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Income Tax Notice Invalid for Failure to Follow Faceless Assessment Procedure
Case Law Details
- Case Name
- Ramachandra Reddy Vs DCIT (Karnataka High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Karnataka High Court
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Ramachandra Reddy Vs DCIT (Karnataka High Court)
The Karnataka High Court addressed a bunch of writ petitions involving a common jurisdictional issue regarding the validity of income tax notices issued by jurisdictional Assessing Officers (JAOs) rather than through a faceless regime.
Background of the Petitions
1. Writ Petition No. 28182 of 2024: An individual assessee filed a return of income for the assessment year 2017-18. Following search and seizure operations on third parties in 2018, the JAO issued a notice under Section 148A(a) of the Income Tax Act, 1961, requesting information regard...
Author Info
Keeping in mind the latest amendments in Finance Act 2026 where in it is amended that even the notices issued by JAO shall be held valid and this amendment is applicable retrospectively w.e.f. 01.04.21 by inserting new sec. 147A.
Therefore, for earlier reassessment years prior to 1.4.2021 , if notices issued by JAO must be treated as without jurisdiction isn’t it?
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