JAO can issue Section 148 notice after Section 132 search: Gujarat HC

Talati And Talati LLP Vs Office of Assistant Commissioner of Income Tax (Gujarat High Court) Gujarat High Court addressed the validity of show-cause notices issued under Section 148 of the Income Tax Act, 1961, in two petitions, Talati And Talati LLP Vs Office of Assistant Commissioner of Income Tax. The core issue was whether a Jurisdictional Assessing Officer (JAO) could issue such notices following a search and seizure under Section 132, or if the process must be exclusively through automated, faceless allocation as per Section 151A and related schemes. The petitioner challenged the notice,...