Faceless Procedure Required for International Tax Reassessment Notices; Non-Compliance Invalidates Assessments.

Notices issued u/s 148 of the Income Tax Act for reassessment proceedings related to international tax charges must comply with the mandatory faceless procedure prescribed in the scheme dated 29.03.2022. The exemption from following the faceless procedure u/s 144B and the CBDT order dated 06.09.2021 is limited to passing assessment orders in cases of central charges and international tax charges, and does not extend to issuing notices u/s 148. The plain and unambiguous language of the scheme, Section 144B(2), and the order does not provide for any such exemption for issuing notices u/s 148. The argument distinguishing between NRIs and Indian citizens is rejected, as the requirement for a faceless procedure applies equally. The principle of ..... .....

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