Facts: The Joint Assessing Officer (JAO) issued a reopening notice u/s 148 of the IT Act, 1961, to the assessee, initiating re-assessment proceedings. The re-assessment was initiated without conducting the mandatory faceless assessment as required u/s 144B of the IT Act. The assessee challenged the notice and proceedings, arguing that the absence of faceless assessment violated the legal requirements, rendering the proceedings unlawful.
Decision: The court quashed the notice issued u/s 148 and the subsequent re-assessment proceedings for not complying with the faceless assessment procedure u/s 144B. The court held that the failure to follow the faceless assessment process made the re-assessment contrary to the law and emphasized that statutory provisions must be strictly adhered to. The court allowed the revenue authorities to reinitiate the re-assessment process if they strictly followed the procedural requirements set out in the IT Act, 1961.