The Taxonation Journal

Insights on Indian tax law.

GST and Income Tax rulings, guides and practical notes from the Taxonation.AI team — written for the professionals who have to draft the reply.

Section 147A Struck DownLatestSec. 147A
Income Tax Module

AP High Court on Faceless Reassessment

The Andhra Pradesh High Court, in Bala Sreenivas Rao Somisetty v. Income Tax Officer, declared Section 147A of the Income-tax Act, 1961, unconstitutional and set aside reassessment proceedings initiated by Jurisdictional Assessing Officers (JAOs). The Court held that the 2022 faceless reassessment scheme required notices under Section 148 to be issued through automated allocation and that Section 147A could not override judicial decisions or cure the underlying jurisdictional defect. The ruling also addressed the insertion of Section 147A into the repealed 1961 Act. The judgment favours taxpayers, although further appellate proceedings may affect its final status.

SShilpa Gupta · 15 Oct 2026
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