Your Section 148 Notice Might Be Void. Here's Why.

Section 151A of the Income-tax Act requires that all reassessment notices under Section 148 be issued through the faceless assessment mechanism operated by the National Faceless Assessment Centre (NFAC). Jurisdictional Assessing Officers (JAOs) cannot bypass this.

In Kankanala Ravindra Reddy and related matters, the Telangana High Court held that Section 148 notices issued directly by a JAO, not through NFAC, are void ab initio. In July 2025, the Supreme Court dismissed the Income Tax Department's Special Leave Petition against the Telangana HC ruling. The position now stands affirmed at the apex level.

NRIs get a lot of Section 148 reassessment notices. The triggers are usually:

For years, these notices were issued by the "International Tax" range JAO in Delhi or Mumbai, not through the faceless NFAC system. The department's position was that international tax cases needed specialist JAO handling and were carved out of the faceless scheme.

The courts disagreed. There is no carve-out in Section 151A for international tax. If your 148 notice came from a JAO's office and not via NFAC, the Telangana HC says it's void. And the Supreme Court has refused to disturb that finding.

Look at the notice itself. Two things tell you if it was JAO-issued or NFAC-issued:

**The issuing authority.** A NFAC-issued notice will explicitly reference the "Faceless Assessment Scheme" and the NFAC system. A JAO notice will name a specific officer and a physical range — "Dy. Commissioner of Income Tax, International Taxation, Circle X, Mumbai" or similar.

**The DIN (Document Identification Number).** NFAC notices carry a DIN prefix that's distinct from JAO-issued notices. Your CA or tax representative can decode this.

If your notice was issued by a JAO directly, you have a procedural defence. The right move is to file a writ petition or raise the Section 151A / 144B mandatory-faceless argument in the 148A reply itself, citing the Telangana HC ruling and the Supreme Court's dismissal of the SLP.

Don't just ignore the notice. That's not how it works. You have to raise the jurisdictional objection in the reply or via a writ. Silence doesn't cancel the notice, it lets the proceedings continue.

Finance (No. 2) Act 2024 tightened the reassessment time limits. Effective 1 September 2024:

The 10-year window is gone. Any notice trying to reopen an assessment year that's more than 5 years old (for big cases) or 3 years old (for smaller cases) is time-barred.

So two defences stack:

1. Is the notice within the revised time limit under Finance Act 2024?

2. Was the notice issued through the faceless mechanism under Section 151A?

A "no" to either one kills the notice. We see 30-40% of old NRI 148 notices failing at least one of these tests now.

**Don't panic. Don't ignore. Don't pay without checking.**

Forward the notice PDF to us. Within a few hours, we'll tell you:

1. Whether it was NFAC or JAO issued

2. Whether it's within the current Finance Act 2024 time limits

3. Whether the Kankanala Ravindra Reddy / Supreme Court SLP dismissal applies to your specific notice

4. What the best next step is, writ, 148A reply, or negotiated resolution

Under Section 288, our CA can become your Authorized Representative. We reply on the portal, appear at any hearings, and file the writ if needed. You don't touch the e-filing portal and you don't fly to India.