Jyoti Sareen v. UOI: Reassessment notices issued by jurisdictional AOs without randomized automated allocation in a faceless manner under section 151A are void.

34. Jyoti Sareen v. UOI:

[2026] 190 taxmann.com 384 (P&H):

A. Y. 2020-21: Date of order 10/09/2026:

S. 147A r.w.ss. 148, 148A and 151A of ITA 1961/

Reassessment — Issuance of notice for re-opening — S. 151A read with the scheme framed thereunder — Notice required to be issued through randomized automated allocation and in a faceless manner — Notice issued by jurisdictional AO, not through randomized automated allocation and in a faceless manner, are invalid and without jurisdiction — Insertion of S. 147A vide Finance Act 2026 w.e.f. 01/04/2021 — With a non-obstante clause without amending section 151A or related scheme — To overturn judicial decisions and circumvent unfavourable rulings — Unconstitutional encroachment on judicial power — S. 147A unconstitutional — Notice issued by jurisdictional AO without using randomized automated allocation and not in faceless manner — Violative of S. 151A and the scheme framed thereunder — Notice under section. 148 held to be invalid.

The Assessee, a practicing Advocate, filed her return of income on 30/09/2020 for A. Y. 2020-21. The return was processed and an intimation under section. 143(1) of the Act was iss