Punjab & Haryana High Court Invalidates Reassessment Notice Issued Outside NFAC Jurisdiction

The transition toward a digitized and transparent tax administration has brought significant procedural shifts in how the Revenue department interacts with the assessee. A cornerstone of this modernization is the faceless assessment regime. Recently, the Hon'ble Punjab and Haryana High Court delivered a crucial ruling in the case of Tej Pratap Singh Vs ITO, reaffirming the mandatory nature of these procedural guidelines. The Court categorically held that reassessment notices must strictly adhere to the jurisdictional boundaries established by the Central Board of Direct Taxes (CBDT).

Background of the Dispute

The legal controversy erupted when the assessee received a reassessment notice for the Assessment Year 2021-2022. The core grievance did not immediately concern the merits of the income escaping assessment, but rather the fundamental jurisdiction of the authority that issued the notice.

The Impugned Notice

The assessee was served with a notice dated 27.03.2025 under Section 148 of the Income Tax Act 1961. This statutory provision empowers the tax department to reopen past assessments if there is reason to believe that any income chargeable to tax has escaped assessment. However, the initiation of such proceedings is heavily guarded by strict procedural prerequisites.