Section 148 Notice Issued by JAO is Non-Est, Should Have Been Issued by FAO: Bombay HC

Paras Mahendra Shah Vs Union of India (Bombay High Court)

The petitioner is an individual. It filed return for assessment year 2020-2021. It was issued notice under section 148 of the Income Tax Act on 31.03.2024, pursuant to order passed under section 148A(d). came to passed. The same was challenged in writ petition. The challenge, amongst other grounds, was on the ground that the notice is issued by the jurisdictional assessing officer (JAO) and not by the faceless assessing officer (FAO) in terms of section 151A of the Act and hence, without jurisdiction.