Can a Jurisdictional Assessing Officer Issue a Reassessment Notice?

The controversy stems from Notification Number 18/2022 issued by the CBDT that deals with a mandatory faceless process for assessment and reassessments. Based upon this, Bombay High Courtc, in Hexaware Technologies Limited,  had held that reassessment notice can be issued only under the Faceless Assessment Scheme and not by the jurisdictional Assessing Officer. The High Courts of Telengana, Karnataka and Madras have, similarly, quashed reassessment proceedings initiated by the Jurisdictional AO. On the other hands, the High Courts at Gujarat and Delhi have held that both the faceless AO as well as Jurisdictional AO have concurrent jurisdiction. The matter is now pending before the Hon'ble Supreme Court of India in a batch of cases, the main one being that of Suryalakshmi Cotton Mills. The judgment of Supreme Court should put the matter to rest although it is possible that a change in the law may be brought about at the forthcoming budget on 01^st  February, 2026. In some of the High Court judgments, revenue has been permitted to pursue the cases they have initiated in case the judgment of the Supreme Court goes in favour of revenue and that seems to be fair.