Reassessment notices issued by JAO instead of FAO are invalid and unsustainable in law: Jodhpur ITAT
The Hon’ble Rajasthan High Court (Jodhpur Bench), in Darshan Dhankani vs. Principal Commissioner of Income Tax (Central), Jaipur & Ors. [Order dated 06.11.2025], has once again reaffirmed the judicial stand that reassessment notices issued by Jurisdictional Assessing Officers (JAO) — instead of the Faceless Assessing Officers (FAO) — are invalid and unsustainable in law.
The Court followed the earlier precedents laid down in Shree Cement Ltd., Sharda Devi Chhajer, and Hexaware Technologies Ltd. (Bombay HC), holding that any reassessment under Section 147/148 must conform to the faceless mechanism notified under the e-assessment scheme (Notification dated 29.03.2022).
This judgment is significant as it reinforces the mandatory and jurisdictional character of the Faceless Assessment Scheme and curtails discretionary deviations by field officers. It also strengthens procedural discipline under the new reassessment framework — ensuring that technology-driven assessments remain consistent with transparency, objectivity, and legal sanctity.
Such clarity from the judiciary will hopefully bring uniformity and predictability to the reassessment process, reducing avoidable litigation on technical grounds.
The copy of the order is as under:
