JAO Has No Jurisdiction – ITAT Quashes 148 Notice Issued Outside Faceless Scheme

Sudhaker Munigeti Vs ITO (ITAT Hyderabad) Hyderabad Tribunal examined legality of reassessment proceedings initiated by the Jurisdictional AO (JAO) despite the statutory mandate of the Faceless Jurisdiction Scheme, 2022. Assessee had not filed return. JAO issued notice u/s 148A(b) on 28.02.2023, passed order u/s 148A(d) on 29.03.2023 & issued notice u/s 148 on the same day. Assessee challenged jurisdiction, arguing that post-2022, reassessment can be initiated only by the Faceless AO, relying heavily on Telangana High Court in Kankanala Ravindra Reddy, subsequent Telangana HC ruling (WP 29...