Order : 1. This writ petition has been preferred by the petitioner under Article 226 of the Constitution of India claiming the following reliefs :- “i. Order dated 11.04.2023 (Annx.4) passed under section 148A(d) so also the notice dated 11.04.2023 (Annx.5) issued under Section 148 leading to Assessment Order and Demand Notice dated 24.12.2024 (Annx.9) passed under section 147 r/w sections 144 & 144-B may all be quashed. ii. It may be declared that the reassessment proceedings are void ab initio. iii. Any other order or direction which this Hon’ble Court deems just and proper may kindly be passed.” 2. Learned counsel for the petitioner submits that for the Financial Year 2018-19 (Assessment Year 2019-20), the petitioner, who owns agricultural land, did not file an income tax return. Consequently, the respondents issued a notice under Section 148A (b) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’), alleging an escapement of income amounting to Rs. 15,12,000/-. The notice (Annexure-2), issued under Section 148A (b) of the Act on 21.03.2023, was delivered on 26.03.2023, as per the postal tracking record on page 123 of the respondents’ reply. Learned counsel further submits that respondent no.3 issued a second notice on 31.03.2023 (Annexure-3), which was delivered on 05.04.2023, as evidenced by the postal tracking record on page 132 of the respondents’ reply. Subsequently, an order was passed under Section 148A (d) of the Act on 11.04.2023. 2.1. Learned counsel contends that Section 148A (b) of the Act prescribes a mandatory time limit of not less than seven days but not exceeding thirty days for the assessee to respond to a show- cause notice. Subsequently, an order was passed under Section 148A (d) of the Act on 11.04.2023. 2.1. Learned counsel contends that Section 148A (b) of the Act prescribes a mandatory time limit of not less than seven days but not exceeding thirty days for the assessee to respond to a show- cause notice. Clause (b) of Section 148A of the Act of 1961 reads as under:- “(b) provide an opportunity of being heard to the assessee, [] by serving upon him a notice to show cause within such time, as may be specified in the notice, being not less than seven days and but not exceeding thirty days from the date on which such notice is issued, or such time, as may be extended by him on the basis of an application in this behalf, as to why a notice under section 148 should not be issued on the basis of information which suggests that income chargeable to tax has escaped assessment in his case for the relevant assessment year and results of enquiry conducted, if any, as per clause (a);” 2.2. Learned counsel for the petitioner further submits that once a statutory time limit has been prescribed under Section 148A (b) of the Act, then it was not open for the Assessing Officer to have given the notice before complying with this requirement. 3. Learned counsel for the respondent is unable to refute the statutory time limit having been violated, but at the same time, he submitted that if both the notices are conjointly read, the time limit is effectively complied with. He further submits that the petitioner did not raise the issue of the statutory time limit violation in the writ petition as prescribed under Section 148A (b) of the Act, and thus, it constitutes concealment of a material ground. 3.1. Learned counsel for the respondent further submits that even if the Court is inclined to quash the impugned notice, then also the consequent assessment order has been passed on 24.12.2024 (Annex.9) and thus, the petitioner cannot avail the remedy for the purpose of getting the notice itself quashed, as the proceedings have progressed beyond that stage. 3.2. 3.1. Learned counsel for the respondent further submits that even if the Court is inclined to quash the impugned notice, then also the consequent assessment order has been passed on 24.12.2024 (Annex.9) and thus, the petitioner cannot avail the remedy for the purpose of getting the notice itself quashed, as the proceedings have progressed beyond that stage. 3.2. Learned counsel for the respondent also submits that the faceless assessment under Section 144B of the Act, which requires electronic proceedings through the assessee’s registered account on the designated portal, could not be conducted because the petitioner’s PAN details were unavailable for about one year. Consequently, the Faceless Assessment Order (FAO) does not apply. He further submits that issue of PAN details and the other issues can be raised by the petitioner at the time of filing an appeal. 4. Learned counsel for the respondent relies on the judgment rendered by Hon’ble Apex Court in the case of K.D. Sharma Vs. Steel Authority of India Ltd. & Ors . Reported in (2008) AIR (SCW) 6654 , particularly paragraph 24, to argue that the petitioner’s failure to raise the statutory time limit violation in the petition amounts to concealment, warranting dismissal of the writ petition. 4.1 In response, learned counsel for the petitioner clarifies that, while there is a dispute regarding the service of the notice, the primary submission before the Court is the respondents’ failure to adhere to the statutory time limit under Section 148A (b) of the Act, which constitutes a statutory violation. 5. After hearing learned counsel for the parties and perusing the record of the case, this Court finds that the respondents’ issuance of the order dated 11.04.2023 (Annexure-4) violates the statutory time limit prescribed under Section 148A (b) of the Act. The second notice, issued on 31.03.2023 and delivered on 05.04.2023, required a minimum of seven days for the petitioner to respond. However, the order dated 11.04.2023 was passed before the expiry of this period, rendering it procedurally defective. This Court holds that the respondents’ failure to comply with the mandatory time limit under Section 148A (b) constitutes a fundamental defect in the proceedings. Consequently, the order dated 11.04.2023 (Annexure-4), the consequential notice (Annexure-5), and the demand notice dated 24.12.2024 (Annexure-9) are illegal and contrary to the provisions of the Act. 6. This Court holds that the respondents’ failure to comply with the mandatory time limit under Section 148A (b) constitutes a fundamental defect in the proceedings. Consequently, the order dated 11.04.2023 (Annexure-4), the consequential notice (Annexure-5), and the demand notice dated 24.12.2024 (Annexure-9) are illegal and contrary to the provisions of the Act. 6. This Court also takes note of a Division Bench judgment in the case of Ladooram v. Central Board of Direct Taxes & Ors. (D.B. Civil Writ Petition No. 8195/2025, dated 12.08.2025), cited by learned counsel for the petitioner, which includes references to Hexaware Technologies Ltd. Vs. Assistant Commissioner of Income-tax , Circle 15(1)(2), Sharda Devi Chhajer Vs. The Income Tax Officer & Another and Shree Cement Limited Vs. Assistant Commissioner of Income-Tax & Others. The respondent’s objection that the absence of PAN details for one year prevented a faceless assessment lacks merit, as the respondents have now traced the petitioner’s PAN details. Accordingly, the respondents are directed to comply with the principles laid down in Ladooram (supra), Hexaware Technologies Ltd. (supra), Sharda Devi Chhajer (supra) and Shree Cement Limited (supra) and act in accordance with these judgments. 7. In view of above, present writ petition is allowed and the order dated 11.04.2023 (Annexure-4), along with the consequential notice (Annexure-5), and the demand notice dated 24.12.2024 (Annexure-9) are quashed and set aside. The respondents are directed to comply with the statutory provisions of the Income Tax Act, 1961 , and the judgments cited above for initiating the process afresh.