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2024 (7) TMI 906

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..... al. For the Respondents : Mr. P. A. Narayanan. ORAL JUDGMENT   (PER G. S. KULKARNI, J.):- 1. Rule. Rule made returnable forthwith. By consent of the parties, heard finally. 2. This writ petition under Article 226 of the Constitution of India, in the context of a notice issued to the petitioner under Section 148A (b) of the Income Tax Act, 1961 (for short, "the Act") and actions taken .....

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..... nates, agents and successors in office; (c) Toforthwith withdraw and/or cancel (i) Notice under section 148 of the Act dated April 12, 2024 (Ex-A); (ii) Order dated April 12, 2024, passed under section 148A (d) of the Act (Ex-B); (iii) Notice under section 148A (b) of the Act dated March 21,2024 (Ex-C); (d) Toforthwith forbear from taking any steps whatsoever pursuant to or in implem .....

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..... o the consequent order under Section 148A (d) and the notice issued to the petitioner under Section 148 of the Act, have been issued by the Jurisdictional Assessing Officer (for short, "JAO"). It is submitted that in view of the faceless scheme notified under Section 151A of the Act by the Central Government vide notification dated 29 March 2022, the JAO did not have an authority to issue the impu .....

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..... e notification dated 29 March 2022 came to the conclusion that the Jurisdictional Assessing Officer would cease to have jurisdiction to issue any notice under Section 148A (b) and to take further actions under Section 148A (d) and Section 148 of the Act, outside the faceless assessment. Learned counsel for the respondents would not dispute this position. Thus, the challenge as raised by the petiti .....

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