The Madras High Court’s decision also underscores the importance of procedural compliance within the framework of the faceless assessment scheme. While the Court acknowledged the procedural lapse in naming the JAO on the notices, it emphasized that such a mistake does not undermine the legitimacy of the assessment process. Instead, the Court deemed this a correctable error, reinforcing the view that technical issues should not derail legitimate proceedings when the substance of the law is being adhered to.
This ruling clarifies that the jurisdiction of the JAO is not undermined in the context of faceless assessments. Even though the faceless scheme allows the FAO to conduct assessments digitally, the JAO retains its jurisdictional role in issuing notices. The Court’s position aligns with the larger framework of ensuring both transparency and fairness in the system, as evidenced by the integration of digital tools with traditional processes.
The judgment is also significant in terms of the broader implications for tax administration. It offers insight into how traditional roles in the tax system, such as those of the JAO, continue to evolve in a digital-first era. While the shift towards faceless assessments aims to streamline and simplify the tax process, the Court’s ruling confirms that the jurisdictional authority of officials like the JAO is still essential to the process, ensuring that the system remains balanced and fair.
In conclusion, the ruling offers clarity to businesses and individuals dealing with faceless assessments, signaling that the interaction between digital processes and jurisdictional powers remains a key element of the tax administration system. The Court’s decision ensures that despite the digitalization of tax procedures, key functions and checks, like the issuance of notices by the JAO, continue to play a crucial role in maintaining the integrity of the process.
