New Delhi, Sept. 11 -- In a significant ruling, the Punjab & Haryana High Court has struck down the newly introduced Section 147A of the Income Tax Act, 1961, which sought to retrospectively clarify the role of the Jurisdictional Assessing Officer (JAO) in reassessment proceedings.

The judgment is likely to bring relief to taxpayers who received reassessment notices from jurisdictional AOs without the automated, faceless allocation mechanism mandated under Section 151A.

However, the ruling does not invalidate every reassessment proceeding. The crucial question remains whether the notice was issued in accordance with the prescribed statutory procedure and whether the requirements relating to faceless assessment were followed.

The decisi...