Notice Under Section 148 Invalid Due to Faceless Mandate Violation

Wellcare International Hospital & Research Institute Pvt. Ltd. Vs ITO (ITAT Chennai) Reopening Quashed: Section 148 Notice by Jurisdictional AO Invalid Post Faceless Scheme The Chennai Bench of the ITAT, in Wellcare International Hospital & Research Institute Pvt. Ltd. v. ITO (AY 2018-19), held that a reassessment initiated through a section 148 notice issued by the Jurisdictional Assessing Officer (JAO) after notification of the Faceless Scheme dated 29.03.2022 is invalid and bad in law. The Tribunal noted that, pursuant to section 151A and the “E-Assessment of Income Escaping Asses...