Jan 2, 2023
The Supreme Court’s order does not finally decide the validity of Section 147A or the JAO/faceless jurisdiction controversy. It has only admitted the Revenue’s appeal and stayed the High Court ruling pending final adjudication.
Accordingly, the constitutional validity of Section 147A and the precise jurisdictional framework for issuing notices under Sections 148/148A remain sub judice before the Supreme Court.
The Supreme Court’s interim order provides an important procedural development, but the final legal position will depend on the Supreme Court’s decision in the main appeal.