JAO-Issued 148 Notice After 29.03.2022 Held Invalid: Entire Reassessment Quashed- Chennai ITAT

Ammapalayam Basuvaptti Primary Agricultural Co-op Credit Society Ltd. Vs ITO (ITAT Chennai) Assessee challenged reassessment u/s 147/148 wherein NFAC denied 80P deduction & made addition of ₹32,43,480. Tribunal first admitted an additional legal ground that the notice u/s 148 dated 06.04.2022 was void ab initio because CBDT Notification 18/2022 (& Scheme under s.151A) mandated that post-29.03.2022 all 148/148A notices must be issued only by Faceless AO, yet here the Jurisdictional AO (JAO) issued the notice. After examining the notice & a long list of precedents, Tribunal held th...