Jurisdiction of the Assessing Officer under the Income Tax Act is limited post-implementation of the Faceless Scheme, invalidating notices issued under Section 148 after March 29, 2022.

ORDER :

1. In this petition, the petitioner seeks the following reliefs:

"i. issue a writ of certiorari or any other writ as the Hon'ble High Court may deem fit and quash the following:

ANNEXURE 'D' Impugned notice dated 21.03.2024 issued by Respondent No.1 under section 148A(b) of the Act for AY 2017-18 in DIN & Notice No. ITBA/AST/F/148A(SCN)/2023-24/1063108868(1)

ANNEXURE 'E' Impugned order dated 30.03.2024 passed by Respondent No.1 under section 148A(d) of the Act for AY 2017-18 in DIN & Order No. ITBA/AST/F/148A/2023-24/1063684881(1)

ANNEXURE 'F' Impugned notice dated 30.03.2024 issued by Respondent No.1 under section 148 of the Act for the AY 2017-18 in DIN & Notice No.ITBA/AST/S/148-1/2023-24/1063685233(1)

ANNEXURE 'M' Impugned assessment order dated 26.03.2025 passed by Respondent No.2 under section 147 read with section 144 read with section 144B of the Act for AY 2017-18 in DIN & Order No.ITBA/AST/S/147/2024-25/1075032590(1)

ANNEXURE 'M1' Impugned computation sheet dated 26.03.2025 issued by Respondent No.2 under section 147 read with section 144 of the Act for AY 2017-18 in DIN & Document No.ITBA/AST/S/216/2024-25/1075032638(1)

ANNEXURE 'M2' Impugned demand notice dated 26.03.2025 issued by Respondent No.2 under section 156 of the Act for AY 2017-18 in DIN & Notice No. ITBA/AST/S/156/2024-25/1075032653(1)

ii. issue any other writ, order or direction to which the Petitioner is found entitled to in the present facts and circumstances and in the interests of justice and equity."

2. Heard learned Senior Counsel for the Petitioner and learned counsel for the respondents and perused the material on record.

3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned Senior Counsel for the petitioner submitted that pursuant to the impugned notice under section 148A(b) of the Income Tax Act, 1961, the respondent No.1 completed the assessment proceedings and passed the Assessment Order for the Assessment year 2017-18 determining the total income of the petitioner as Rs.7,52,26,133/-.

4. Aggrieved by the said Assessment Order, the petitioner has preferred statutory appeal before the respondent No.3 - appellate authority, which is still pending adjudication.

5. Meanwhile, decision of a Co-ordinate Bench of this Court in the case of Ramachandra Reddy Ravi Kumar Vs. Deputy Commissioner of Income Tax , W.P. No. 17352/2022 dated 28.08.2025, has disposed of the petitions quashing the show cause notice on the ground that the Assessing Officer did not have jurisdiction to issue the notice under section 148 of the Act in the light of Section 151A of the Income Tax Act, 1961 and the Notification pursuant thereto which provided for issuance of notice only by the faceless authority of the respondent. It is therefore submitted that the impugned notice under section 148 of the Act and assessment orders, etc., may be set aside and the present petition be disposed of in terms of the said order. It is also submitted that the necessary directions may be issued to the CIT(A) to dispose of the Appeals, as having become academic/infructuous reserving liberty in favour of the petitioner to seek revival/restoration of the appeal/s if the occasion so arises.

6. Per contra, learned counsel for the respondent -Revenue submits that there is no merit in the petition and the same is liable to be dismissed.

7. A perusal of the material on record will indicate that in Ramachandra Reddy Ravi Kumar's case supra a Coordinate Bench of this Court has held as under:

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