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Punjab and Haryana HC: JAO-Issued Section 148 Reassessment Notice Invalid

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Summary

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  • The Punjab and Haryana High Court has dismissed the Revenue's appeal challenging the ITAT's quashing of a Section 148 reassessment notice issued by the Jurisdictional Assessing Officer (JAO) on March 27, 2023.
  • The court noted that all substantial questions raised by the Revenue had already been addressed against it in the Jyoti Sareen Vs Union of India case decided on September 10, 2026.
  • Key arguments included whether notices under Section 148 must be issued exclusively through a faceless mechanism, as per recent legislative changes.
  • This ruling reinforces the limitations on JAO's authority in reassessment procedures, potentially impacting future tax assessments under the faceless regime.

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