Reassessment Jurisdiction Dispute under S 147 and 148

The Nagpur Bench of the Income Tax Appellate Tribunal examined a challenge to the validity of reassessment proceedings initiated under Sections 147 and 148 of the Income-tax Act in the backdrop of the faceless reassessment regime introduced under Section 151A and the E-Assessment of Income Escaping Assessment Scheme, 2022. 

While the assessee contended that the notice under Section 148 was void because it had been issued by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer, the Tribunal refrained from deciding the legal issue conclusively in view of the pendency of the matter before the Supreme Court. 

The matter was consequently remanded to the Commissioner (Appeals) for fresh adjudication on both legal and factual aspects through a reasoned and speaking order.