Section 147A — the law in short
What the courts have decided on section 147A, in one screen. Read this first; open an entry when you need the facts, the reasoning and the source.
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ITO v Tej Partap Singh
Supreme CourtCuts both ways
The High Court quashed my s.148 notice because the ward officer issued it instead of the faceless unit. Does that judgment still stand?
No, not as it stands. On 10 April 2026 the Supreme Court set aside the High Court judgments that had quashed notices issued by the jurisdictional Assessing Officer, because s.147A, inserted by the Finance Act 2026 with effect from 1 April 2021, now defines the Assessing Officer for ss.148 and 148A as an officer other than the National Faceless Assessment Centre and the assessment units in s.144B(3). The Court remitted the matters, left the validity, scope, effect, retrospectivity and applicability of s.147A open for the High Courts, and stayed further assessment and reassessment proceedings in the meantime.
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Synokem Pharmaceuticals Ltd v ACIT
High CourtHelps departmentValidity unconfirmed
The Supreme Court remitted my JAO reassessment case and gave four weeks to amend. Will the High Court actually let me amend to challenge s.147A?
Not as of right. The Delhi High Court refused. Delhi had already held in T.K.S. Builder Pvt. Ltd. that the Faceless Assessing Officer and the Jurisdictional Assessing Officer have concurrent jurisdiction, so s.147A took nothing away from this petitioner; the writ petition had in any event already been dismissed. The court held that whatever little remained to be argued had been washed away by the amendment and rejected the amendment application as misconceived.
Listed strongest first: Supreme Court, then High Court, then Tribunal, then CBDT. Nothing here has yet been read in full by a chartered accountant — open an entry to see where it came from.