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Case lawConcepts › Who may issue the s.148 notice now: s.151A, s.147A, and where the fight actually stands

Who may issue the s.148 notice now: s.151A, s.147A, and where the fight actually stands

Is the point that my ward officer issued the s.148 notice instead of the faceless unit still worth taking, and what happens if the assessment is already complete?

Is the point that my ward officer issued the s.148 notice instead of the faceless unit still worth taking, and what happens if the assessment is already complete?

It is open, not settled, and it is no longer a construction point. Section 147A, inserted by the Finance Act 2026 with effect from 1 April 2021, defines the Assessing Officer for ss.148 and 148A as an officer other than the National Faceless Assessment Centre and the s.144B(3) units, notwithstanding any judgment of any court or s.151A or any scheme under it. On 10 April 2026 the Supreme Court set aside the High Court judgments that had quashed such notices, remitted them so that the validity and retrospectivity of s.147A could be argued, and stayed further proceedings meanwhile.

This is an explainer, not a judgment. It states the law in our own words, which is exactly why it needs checking. Everything below was written from the sources listed at the foot of this page, and no chartered accountant has yet signed it off. Read the source before you rely on it in a reply or an appeal.

The dispute began with the Scheme notified under s.151A on 29 March 2022. One line of High Court authority read it as requiring reassessment notices to issue through the faceless mechanism, so that a notice from the jurisdictional Assessing Officer was without jurisdiction - the Bombay High Court in Hexaware Technologies is the entry in this library on that side. The other read the faceless architecture as operating alongside the jurisdictional officer, on the footing that s.144B is procedural and is not the source of the power to reassess - the Delhi High Court in T.K.S. Builders is the entry on that side. Both entries remain in the library, and both must now be read with what follows.

Section 147A was inserted by the Finance Act 2026 and given effect from 1 April 2021. On the reports I could reach, it provides that for ss.148 and 148A the Assessing Officer means, and shall always be deemed to have meant, an officer other than the National Faceless Assessment Centre and any assessment unit referred to in s.144B(3), and it operates notwithstanding any judgment or order of any court, s.151A, or any scheme framed under s.151A. The memorandum reasoning is that pre-notice satisfaction was always intended to be the jurisdictional officer's function, with the faceless machinery engaged at the assessment stage under s.144B, and that the amendment removes the uncertainty created by the divergent judgments. I have not read the enacted text of s.147A itself; what is set out here comes from commentary and from professional-firm notes.

On 10 April 2026 the Supreme Court, in the batch reported as ITO v. Tej Partap Singh, set aside the High Court judgments that had quashed jurisdictional-officer notices and remitted them. The assessees were given four weeks to amend their petitions to challenge s.147A, the Revenue three weeks to reply, further assessment and reassessment proceedings under the impugned notices were stayed during the pendency of the writ petitions, and the High Courts were asked to decide preferably by 30 September 2026. The Court expressly did not decide the validity, scope, effect, retrospectivity or applicability of s.147A. It has since disposed of connected batches in the same terms, most recently in ACIT v. Rudra Alloys (P.) Ltd. on 19 June 2026.

So the honest statement of the position, as at this entry's writing, is that the taxpayer-favouring line has been legislatively displaced and judicially set aside, the displacement is itself under constitutional challenge, and no court has yet ruled on that challenge. A practitioner who tells a client the point is dead is wrong; a practitioner who tells a client the point is good is also wrong.

The second question - what happens where the assessment has already been completed on the back of such a notice, as against a notice still at show-cause stage - has no clean answer in the material I could reach, and the two reported approaches point in different directions. Where courts on the faceless-only line quashed the notice, they generally treated everything built on it as falling with it: the Bombay High Court is reported in Hitesh Ramniklal Shah v. ACIT to have quashed the notices "along with all reassessment orders granted pursuant thereto and all consequential demand notices and penalty notices", and a Rajasthan High Court decision reported as Bharat Kumar v. DCIT quashed both a notice of 27 March 2024 and the assessment order of 23 March 2025 made on it. Against that, the Rajasthan High Court in Ashok Gupta v. DCIT (D.B. Civil Writ Petition No. 19507 of 2025, 15 January 2026) is reported to have declined to entertain the writ at all because the assessee had already filed an appeal before the CIT(A), and to have sent the jurisdictional ground to be decided in that appeal rather than deciding it itself. Each of those rests on a single source. What they suggest, and it is no more than a suggestion, is that the difference is one of posture rather than principle: a completed assessment brings with it an alternative remedy, and a court that has an appeal in front of it is likely to send the point there.

The practical significance of a completed assessment is different again after the Supreme Court's order. The interim stay it granted is of further assessment and reassessment proceedings; it does not on its face undo an assessment already framed. If yours is already framed, the appeal is where the ground has to be kept alive, and it has to be kept alive as a jurisdictional ground so that it is not treated as waived.

Why it matters

This was for three years the most commonly taken reassessment ground in writ petitions, and a great deal of pending litigation - and a good many appeals where the ground is the only ground - now depends on whether a retrospective amendment can validate proceedings that several High Courts had held to be without jurisdiction. Advice given on this point has a short shelf life, and anything written before April 2026 needs re-checking before it is used.

What to do

Where people go wrong

Unsettled, or not pinned down. The enacted text of s.147A was not read - it is described here from commentary. No court has yet ruled on the validity or retrospectivity of s.147A, so the substantive question is unanswered. On completed assessments, the three decisions named each rest on a single source and none of them was decided with s.147A in view; there is no authority here on whether a completed assessment survives if s.147A is struck down, or on limitation for a fresh notice in that event. The reported date of the Bombay decision in Hitesh Ramniklal Shah (7 May 2026) does not sit easily with the composition of the Bench named, and should be verified before that case is cited.

Authorities on these sections

Judgments in this library that turn on the same provisions.

Where this came from

Every page in this library links to what it was written from, so you can check it rather than take our word for it.