u surp the legal provisions to their own satisfaction and c onvenience causing hardship t o the assessees. It also leaves c onfusion in the minds of the ta x payers. In the opinion of this C ourt, instructions and circula r s can be issued only for the p urpose of supplementing the statutory provisions and for t heir implementation. 1 7. In view of the aforesaid disc u ssion, there is no occasion to d istinguish or take a different vi e w as suggested by the learned c ounsel for the revenue from w h at has already been held by t he Coordinate Bench. 1 8. Keeping in view the law l aid down by the Coordinate B ench (supra), notices issued by the JAO under Section 148 of t he Act, 1961 and the proceedings initiated thereafter without c onducting the faceless assessm e nt as envisaged under Section 1 44B of the Act, 1961, have be e n found to be contrary to the p rovisions of the Act, 1961 a n d accordingly notices dated 2 8.02.2023, 16.03.2023, 20.03.2 0 24 and 30.03.2023 and order d ated 30.03.2023, are set aside fo r want of jurisdiction. 1 9. The respondents-revenue w o uld be, however, at liberty to f ollow the procedure as laid d o wn under the Act, 1961 and p roceed accordingly, if so advis e d. 2 0. All the writ petitions are allo w ed. The interim order passed b y the Court shall stand merged w ith the present order.”
