1. On oral mentioning, Diary Nos. 57737/2025, 37087/2025,
57395/2025, 55409/2025 & 32669/2025 are taken on Board and
heard along with this batch of matters.
2. Permission to appear and argue in-person is allowed.
3. Delay condoned.
4. Leave granted.
5. In a nutshell, the genesis of this batch of thousands of
appeals originates from reassessment proceedings initiated
under the Income-tax Act, 1961 (IT Act). The impugned
judgments of several High Courts have set aside orders
passed under Section 148A(d) of the IT Act and consequential
notices issued under Section 148 of the IT Act on the ground
that they were issued by the Jurisdictional Assessing
Officer(s) (JAO), rather than through the prescribed
faceless mechanism or competent Faceless Assessment
Officer(s) (FAO). It is pertinent to note that certain other
High Courts, while considering the same issue, have adopted
a contrary view and upheld the authority of the JAO.
