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June 2024

Validity of Notice under Section 148 Issued By the JAO

By Pradip Kapasi | Gautam Nayak | Bhadresh Doshi, Chartered Accountants
Reading Time 25 mins


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  1st 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 29th 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