Validity of Notice under Section 148 Issued By the JAO

ISSUE FOR CONSIDERATION

Over the last few years, the Government has adopted a policy of making several processes under the Act fully faceless, which otherwise required interface with the taxpayers. In line with this objective, Section 151A was inserted with effect from  1^st November, 2020, which provides for notification of a faceless scheme for the following purposes, namely —

•  assessment, reassessment or re-computation under section 147;
•  issuance of notice under section 148;
•  conducting of enquiries or issuance of show-cause notice or passing of order under section 148A;
•  sanction for issue of such notice under section 151.

Notification No. 18/2022 was issued notifying the ‘e-Assessment of Income Escaping Assessment Scheme, 2022’ (Scheme) under Section 151A with effect from 29^th March, 2022. The scope of this scheme as provided in Clause 3 of the Scheme is reproduced below for reference —

Scope of the Scheme

3. For the purpose of this Scheme, —

(a) assessment, reassessment