Mohammed Ibrahim Ali Vs Assessment Unit (Telangana High Court)
Telangana High Court Quashes Reassessment Proceedings Initiated by Jurisdictional Assessing Officers Post Faceless Scheme
The High Court for the State of Telangana, in a significant batch of writ petitions led by Mohammed Ibrahim Ali vs. Assessment Unit, National Faceless Assessment Centre, delivered an important ruling concerning reassessment proceedings under Sections 148A and 148 of the Income-tax Act, 1961.
The Division Bench comprising Aparesh Kumar Singh and G. M. Mohiuddin held that reassessment proceedings initiated by Jurisdictional Assessing Officers (JAOs) after the implementation of the Faceless Assessment Scheme on 29.03.2022 were without jurisdiction and liable to be quashed.
Core Issue
The common legal issue was:
Whether, after the Faceless Assessment Scheme notified under Section 151A on 29.03.2022, reassessment proceedings under Sections 148A and 148 could still be initiated by the Jurisdictional Assessing Officer (JAO), instead of the Faceless Assessing Officer (FAO).
The Court answered this in favour of the assessees.
What the Court Held
The Bench comprising Aparesh Kumar Singh and G. M. Mohiuddin held:
- After the Faceless Scheme became operational on 29.03.2022, reopening proceedings had to be initiated through the Faceless Assessment mechanism.
- Since the notices in these cases were issued by the JAO, they suffered from lack of jurisdiction.
- The issue was already settled by earlier Telangana High Court judgments, especially:
- Kankanala Ravindra Reddy v. Income Tax Officer
- W.P. No.26304 of 2024 decided on 28.04.2025.
Accordingly, the Court:
- quashed the notices issued under Section 148A,
- quashed the notices under Section 148,
- and also quashed consequential assessment orders and penalty proceedings.
Important Reasoning
