Reassessment Fails When Jurisdictional Officer Issues Section 148 Notice

Ankit Jain Vs ACIT (ITAT Hyderabad) JAO Oversteps, Reopening Collapses: Faceless Mandate Breached Post-29-03-2022, Only FAO Can Issue 148—ITAT Quashes Reassessment The Hyderabad ITAT allowed the Assessee’s appeal and quashed the reassessment framed u/s 147 r.w.s. 144B, holding that the very initiation of proceedings was without jurisdiction. The Tribunal found that the order u/s 148A(d) dated 30-03-2022 and the notice u/s 148 issued on the same date were passed by the Jurisdictional Assessing Officer (JAO), whereas CBDT Notification No.18/2022 dated 29-03-2022, issued u/s 151A, mandates fa...