The core of the petitioner’s argument centered on the claim that the notice under Section 143(2) was issued by an officer who lacked the authority to do so. Furthermore, the petitioner asserted that even if the officer were deemed a prescribed authority, the issuance of the notice should be considered invalid.

Section 143(2) of the Act outlines the conditions under which an Assessing Officer (AO) or a prescribed income-tax authority may issue notices after a tax return has been filed. The law states that such a notice is required if the officer deems it necessary to ensure the accuracy of the income reported or the tax paid. Notably, this section allows either the AO or a prescribed authority to issue notices.

The court considered the petitioner’s arguments and referenced Section 12E of the Income Tax Rules, 1962, which empowers the Central Board of Direct Taxes (CBDT) to authorize income tax officers to act as prescribed authorities. The court noted that the CBDT had indeed issued notifications in 2022, granting authority to specific officers for the purpose of issuing notices under Section 143(2).

The court concluded that the Assistant Commissioner of Income Tax involved in the case was duly authorized to issue the notice in question, thereby refuting the petitioner’s claim of jurisdictional impropriety.

Further arguments made by the petitioner, including the assertion that only officers from the National Faceless Assessment Centre (NaFAC) could issue such notices, were found to be without merit. The court maintained that the provisions of the Act and the rules do not limit this authority to NaFAC officers alone.

Additionally, the petitioner contended that the notices issued under Section 142(1) were beyond the limitation period; however, the court determined that as the initial notice under Section 143(2) was valid, the subsequent notices issued were also within jurisdiction.

Ultimately, the court dismissed the petition, concluding that the AO acted within their authority and that the notices issued were valid. The ruling underscores the importance of jurisdictional clarity in tax assessments and affirms the powers granted to the CBDT in designating income tax authorities. The petitioner's failure to establish grounds for the challenge led to the dismissal of the case, highlighting the court's adherence to statutory provisions.