“faceless assessment”

Assessment ProceduresSection 144BSection 144B2,420 judgments

The decision most relied on for faceless assessment is Kankanala Ravindra Reddy v. ITO (156 Taxmann.com 178), cited in 213 judgments on BharatTax.

Leading authorities on faceless assessment

Kankanala Ravindra Reddy v. ITO

156 Taxmann.com 178 · 2023 · High Court

213

citing judgments

A notice issued under section 148 of the Income Tax Act is invalid if the Income Tax Department fails to follow the prescribed procedures, including obtaining the necessary approvals under section 151 or adhering to the faceless assessment scheme mandates under section 151A.

Jatinder Singh Bhangu v. Union of India

165 Taxmann.com 115 · 2024 · High Court

106

citing judgments

The faceless assessment scheme under Section 151A applies from the stage of issuing show cause notices under Sections 148 and 148A, and non-compliance with the scheme or related notifications vitiates the subsequent assessment proceedings. Assessment proceedings are considered to commence upon the issuance of such a show cause notice.

Ram Narayan Sah v. Union of India

163 Taxmann.com 478 · 2024 · High Court

citing judgments

A notice under section 148 of the Income-tax Act, 1961, cannot be issued by the Jurisdictional Assessing Officer after the introduction of faceless assessment under Section 151A read with Section 144B. Such a notice is invalid as it defeats the object of faceless assessment and is not in consonance with CBDT notifications.

T.K.S. Builders (P) Ltd. v. ITO

469 ITR 657 · 2024 · High Court

citing judgments

Section 144B of the Income Tax Act does not completely divest the Jurisdictional Assessing Officer (JAO) of their power to assess or reassess, even with the introduction of the Faceless Reassessment Scheme.

Triton Overseas (P) Ltd. v. Union of India

156 Taxmann.com 318 · 2023 · High Court

citing judgments

A notice under Section 148 for income escaping assessment issued by the Jurisdictional Assessing Officer is invalid if it does not comply with Section 151A and relevant CBDT notifications concerning faceless assessment.

Pvt. Ltd. v. DCIT

466 ITR 474 · 2024 · High Court

citing judgments

Reassessment notices under Section 148A, issued in the context of faceless assessment proceedings, must be issued by the designated Faceless Assessing Officer and not by a Jurisdictional Assessing Officer.

Mark Studio India (P.) Ltd. v. Income-tax Officer, High Court of Madras

169 Taxmann.com 542 · 2024 · High Court

citing judgments

The National Faceless Assessment Centre (NaFAC) does not have the power to issue notices under Section 148 or 148A of the Income Tax Act. Its jurisdiction for assessment or reassessment begins only from the stage of issuing notices under Section 142(1) or 143(2).

Samp Furniture (P) Ltd. v. ITO

165 Taxmann.com 581 · 2024 · High Court

citing judgments

The issuance of a notice under section 148A, including the order under section 148A(d), is a mandatory procedural step before reassessment proceedings can be initiated under section 147/148. Failure to comply with this requirement renders the subsequent reassessment proceedings invalid.

Judgments citing faceless assessment

Tikona Trust, Mumbai vs. Assistant Director of Income Tax, CPC, Bangaluru

In the result of the appeal of the assessee is partly allowed

ITA 1117/MUM/2022[2018-19]Status: DisposedITAT Mumbai21 Nov 2022AY 2018-19

Bench: Shri Baskaran Br, Am & Shri Aby T. Varkey, Jm आयकरअपीलसं/ I.T.A. No.1117/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2018-19) Tikona Trust बिधम/ Assistant Director Of 3A, 3Rd Floor Corpora, Lbs Marg Income Tax, Cpc Vs. Bhandup West, Cpc, Bangaluru, Mumbai-400078 Karnataka- 560500

For Appellant: Shri .Vimal PunamiyaFor Respondent: Shri. V.K. Chaturvedi, Sr AR

Section 139(1)Section 139(3)Section 234BSection 41Section 41(1)

previous eight years claimed by the Appellant. 3. On the facts and in the circumstances of the case the Id. CIT (A), National Faceless Assessment Centre, erred in confirming the disallowance of loss of Rs. 1,17,04,178/- claimed by the Appellant. 4. On the facts ... circumstances of the case the Id CIT (A), National Faceless Assessment Centre, erred in appreciating the fact that as per the Intimation for the A.Y. 2017-18 the loss of Rs.61,11,994/- was already determined by the CPC as allowable loss. Hence, the Appellant was entitled

M/S. Radisys India Limited (Formerly Known As Radisys India Private Limited), Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 5(1)(1), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 190/BANG/2022[2017-18]Status: DisposedITAT Bangalore18 Nov 2022AY 2017-18

For Appellant: Shri Mahveer C Jain, A.RFor Respondent: Shri Binod Kumar Singh, D.R

Section 143(3)Section 144BSection 144C(13)

which is beyond the period of limitation. On a query being raised asking for the date of receipt of DRP directions by the National Faceless Assessment Centre, the assessee did not have any evidence to place in order to substantiate its plea of a belated order passed by the Ld.AO

Ab Inbev Gcc Services India Private Limited (Earlier Known As Gcc Services India Private Limited), Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee stands partly allowed as indicated hereinabove

ITA 290/BANG/2022[2017-18]Status: DisposedITAT Bangalore14 Nov 2022AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 290/Bang/2022 Assessment Year : 2017-18 M/S. Ab Inbev Gcc Services India Pvt. Ltd., (Earlier Known As Gcc Services India Pvt. Ltd.), The Deputy 12Th & 13Th Floor, Commissioner Of Peridot Block, Bagmane Income Tax, World Technology Centre Circle 3(1)(1), Sez, Vs. Bangalore. Marthalli Road, Kr Puram, Bangalore – 560 048. Pan: Aafcg8223M Appellant Respondent Assessee By : Shri Chavali Narayan, Ca : Dr. Manjunath Karkihalli, Revenue By Cit-Dr Date Of Hearing : 20-09-2022 Date Of Pronouncement : 14-11-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Passed By The Nfac, Delhi Dated 21/02/2022 For A.Y. 2017-18 On Following Grounds Of Appeal:

For Appellant: Shri Chavali Narayan, CA

Section 115JSection 143(1)Section 244ASection 270ASection 92B

days. Page 5 of 17 IT(TP)A No. 290/Bang/2022 2.5 Subsequently, the draft assessment order dated 06/04/2021 was passed by the National Faceless Assessment Centre (NFAC'). In the said order the NFAC proposed to make the following variations to the returned income of the Assessee: Amount Particulars

Ratanlal Jaitlia HUF, Mumbai vs. CIT, Faceless

In the result, this appeal by the assessee is allowed for statistical purpose

ITA 232/MUM/2022[2012-13]Status: DisposedITAT Mumbai07 Nov 2022AY 2012-13

Bench: Shri S. Rifaur Rahman, Am & Ms. Kavitha Rajagopal, Jm Ratanlal Jaitlia Huf National Faceless Assessment 602, Rajendra Ratna, Mahesh Nagar, Centre, Ward 31(1)(6), Sv Road, Goregaon (W), Vs. Mumbai Mumbai-400 062

For Appellant: Shri Mukesh Maheshwari

Section 144Section 154Section 250Section 69Section 69A

INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SHRI S. RIFAUR RAHMAN, AM AND MS. KAVITHA RAJAGOPAL, JM Ratanlal Jaitlia HUF National Faceless Assessment 602, Rajendra Ratna, Mahesh Nagar, Centre, Ward 31(1)(6), SV Road, Goregaon (W), Vs. Mumbai Mumbai-400 062 PAN/GIR No. AAEHR 1272 B (Appellant) : (Respondent

Gundurao Suryavanshi Madhukar (Late) by L/R Rohit M. Suryavanshi, Bengaluru vs. Deputy Commissioner of Income Tax, CPC, Bangalore

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 692/BANG/2022[2017-18]Status: DisposedITAT Bangalore04 Nov 2022AY 2017-18

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Year : 2017-18

For Appellant: Shri S.K. Sridhar, CAFor Respondent: Shri Gudimella V.P. Pavan Kumar, Jt.CIT(DR), ITAT

Section 194CSection 57

Pronouncement : 04.11.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is against the order of the CIT(Appeals), National Faceless Assessment Centre, Delhi [NFAC] , Delhi dated 10.6.2022 for the assessment year 2017-18. 2. The assessee was the owner of two commercial properties and was deriving

Income Tax Officer, Ward-1 & Tps, Shivamogga vs. M/S. Manasa Medicals, Shivamogga

In the result, the appeal of the revenue is dismissed

ITA 552/BANG/2022[2017-18]Status: DisposedITAT Bangalore31 Oct 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2017-18

For Appellant: Shri Gudimella V P Pavan KumarFor Respondent: Shri S.V. Ravishankar, Advocate

Section 148ASection 68

Padmavathy S., Accountant Member This appeal by the revenue is against the order of CIT(Appeals), National Faceless Assessment Centre, Delhi [NFAC] dated 2.8.2021 for the AY 2017-18. 2. The revenue raised the following grounds:- 1. "Whether in the facts and circumstances of the case

M/S. Biesse Manufacturing Company Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bengaluru

In the result, the appeal of the assessee is partly allowed

ITA 338/BANG/2021[2016-17]Status: DisposedITAT Bangalore31 Oct 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri, Tata Krishna, AdvocateFor Respondent: Shri Sankar K. Ganeshan, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 234ASection 234BSection 92C

hearing : 19.10.2022 Date of Pronouncement : 31.10.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is against the order of National Faceless Assessment Centre, Delhi [NFAC] dated 21.4.2021 passed u/s. 143(3) r.w.s.144C (13) of the Income-tax Act,1961 [the Act] for the assessment year

Ajit Vasant Pai, Bangalore vs. Deputy Commissioner of Income Tax, CPC, Bangalore

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 741/BANG/2022[2017-18]Status: DisposedITAT Bangalore28 Oct 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2017-18

For Appellant: Shri H. Anil Kumar, CAFor Respondent: Shri K R Narayana, Addl. CIT(DR)(ITAT), Bengaluru

Section 139Section 139(1)Section 139(1)(a)Section 139(3)Section 139(5)Section 142Section 143(1)(a)Section 154

Vasudevan, Vice President This appeal by the assessee is against the order of CIT(Appeals), National Faceless Assessment Centre, Delhi [NFAC] dated 30.06.2022 for the assessment year 2017-18. 2. The Assessee is an Individual and a Partner in the Firm V M Pal & Co (PAN:AACFV9074F

Deputy Commissioner of Income Tax, Circle-2(2)(1), Bangalore vs. M/S. Spoorthi Constructions, Bangalore

In the result, the appeal of the revenue is allowed for statistical purposes and the CO is partly allowed

ITA 507/BANG/2022[2015-16]Status: DisposedITAT Bangalore28 Oct 2022AY 2015-16

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2015-16

For Appellant: Shri Sagar, CAFor Respondent: Shri Gudimella V P Pavan Kumar

Section 143(2)Section 41(1)

Padmavathy S., Accountant Member This appeal of the revenue and cross objections by the assessee is against the order of CIT(Appeals), National Faceless Assessment & CO No.3/Bang/2022 Page 2 of 9 Centre, Delhi [NFAC] dated 4.4.2022 for the assessment year 2015- 16. The revenue raised the following grounds:- “1. Whether

Rajarathnam'S Jewels, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-1(1), Bangalore

In the result, appeal by the Assessee is dismissed

ITA 370/BANG/2022[2013-14]Status: DisposedITAT Bangalore28 Oct 2022AY 2013-14

Bench: Shri N. V. Vasudevan & Shri Laxmi Prasad Sahuassessment Year : 2013-14

For Appellant: Shri. H. Anil Kumar, CAFor Respondent: Shri. K. R. Narayana, Addl. CIT(DR)(ITAT), Bengaluru

Section 133ASection 143(3)

Shri Laxmi Prasad Sahu, Accountant Member: This is an appeal by the assessee directed against the Order of Assessment dated 16.03.2022 of National Faceless Assessment Centre, Delhi, (hereinafter referred to as the Assessing Officer, “AO” in short) passed under section 143(3) of the Income

Pivotree Solutions India Private Limited (Formerly Known As Bridge Sgi Solutions India Private Limited), Bengaluru vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bangalore

In the result, both the appeals by the assessee are dismissed

ITA 799/BANG/2022[2019-20]Status: HeardITAT Bangalore21 Oct 2022AY 2019-20

Bench: Smt. Beena Pillai & Ms. Padmavathy S

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Padmavathy S., Accountant Member These appeals by the assessee are against the orders of the CIT(Appeals), National Faceless Assessment Centre, Delhi [NFAC] dated 26.11.2021 and 7.9.2021 for the assessment years 2018-19 and 2019-20 respectively. ITA Nos. 798 & 799/Bang/2022 Page 2 of 10 2. There is a delay

Pivotree Solutions India Private Limited (Formerly Known As Bridge Sgi Solutions India Private Limited), Bengaluru vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bangalore

In the result, both the appeals by the assessee are dismissed

ITA 798/BANG/2022[2018-19]Status: HeardITAT Bangalore21 Oct 2022AY 2018-19

Bench: Smt. Beena Pillai & Ms. Padmavathy S

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Ramakrishnappa Nagaraj, Bangalore vs. Deputy Commissioner of Income Tax, Circle-6(3)(1), Bangalore

In the result, the appeal by the assessee is dismissed

ITA 795/BANG/2022[2018-19]Status: HeardITAT Bangalore21 Oct 2022AY 2018-19

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Year : 2018-19

For Appellant: Smt. Sheetal Borkar, AdvocateFor Respondent: Shri K R Narayana, Addl.CIT(DR)(ITAT), Bengaluru

Section 139(1)Section 143(1)Section 2(24)(x)Section 34(1)(iv)Section 36(1)(iv)Section 36(1)(va)Section 43B

Padmavathy S., Accountant Member This appeal by the assessee is against the order of the CIT(Appeals), National Faceless Assessment Centre, Delhi [NFAC] dated 27.09.2022 for the assessment year 2018-19. 2. The only issue in this appeal is regarding disallowance of delayed payment of employee contribution to Employees State

Jssmvp Employees House Building Cooperative Society, Mysore vs. The Assistant Commissioner of Income Tax, Circle-2(1), Mysore

In the result, the appeals are allowed in favour of the assessee for statistical purposes

ITA 781/BANG/2022[2013-14]Status: DisposedITAT Bangalore21 Oct 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Shri K.R. Narayana, Addl.CIT(DR)(ITAT), Bengaluru

Section 148Section 234ASection 4

Padmavathy S., Accountant Member These appeals are against the orders of Commissioner of Income- Tax (Appeals), National Faceless Assessment Centre, Delhi [NFAC] dated 7.7.2022 for the assessment years 2008-09, 2009-10, 2012-13 & 2013-14. 2. The assessee is a house building cooperative society exclusively constituted for the benefit

Jssmvp Employees House Building Cooperative Society, Mysore vs. The Assistant Commissioner of Income Tax, Circle-2(1), Mysore

In the result, the appeals are allowed in favour of the assessee for statistical purposes

ITA 780/BANG/2022[2012-13]Status: DisposedITAT Bangalore21 Oct 2022AY 2012-13

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Shri K.R. Narayana, Addl.CIT(DR)(ITAT), Bengaluru

Section 148Section 234ASection 4

Jssmvp Employees House Building Cooperative Society, Mysore vs. The Assistant Commissioner of Income Tax, Circle-2(1), Mysore

In the result, the appeals are allowed in favour of the assessee for statistical purposes

ITA 779/BANG/2022[2009-10]Status: DisposedITAT Bangalore21 Oct 2022AY 2009-10

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Shri K.R. Narayana, Addl.CIT(DR)(ITAT), Bengaluru

Section 148Section 234ASection 4

Jssmvp Employees House Building Cooperative Society, Mysore vs. The Assistant Commissioner of Income Tax, Circle-2(1), Mysore

In the result, the appeals are allowed in favour of the assessee for statistical purposes

ITA 778/BANG/2022[2008-09]Status: DisposedITAT Bangalore21 Oct 2022AY 2008-09

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Shri K.R. Narayana, Addl.CIT(DR)(ITAT), Bengaluru

Section 148Section 234ASection 4

Indauto Filters, Bengaluru vs. Assistant Director of Income Tax, CPC, Bangalore

In the result, the appeal by the assessee is allowed

ITA 719/BANG/2022[2016-17]Status: DisposedITAT Bangalore21 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2016-17

For Appellant: Shri K G Acharya, CAFor Respondent: Shri K.R. Narayana, Addl.CIT(DR)(ITAT), Bengaluru

Section 139(5)Section 143(1)Section 32

Pronouncement : 21.10.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is against the order of the CIT(Appeals), National Faceless Assessment Centre, Delhi [NFAC] , Delhi dated 15.7.2022 for the assessment year 2016-17. 2. The only issue contended by the assessee through various grounds of appeal

Dover India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, appeal of the Assessee is partly allowed

ITA 460/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Oct 2022AY 2017-18

Bench: Shri N. V. Vasudevan & Shri Chandra Poojariit(Tp)A No.460/Bang/2022 Assessment Year : 2017-18 M/S. Dover India Private Limited, Vs. Dcit, Bagmane Laurel, 1St Floor, Circle – 2(1)(1), Block C, Bagmane Tech Park, Bengaluru. C. V. Raman Nagar, Bengaluru – 560 093. Pan : Aaaci 3920 N Appellant Respondent Assessee By : Shri. Chavali Narayanan, Ca Revenue By : Capt. Pradeep Arya, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 03.10.2022 Date Of Pronouncement : 21.10.2022 O R D E R Per N. V. Vasudevanthis Appeal By The Assessee Is Directed Against The Final Order Of Assessment Dated 29.03.2022 Of National Faceless Assessment Centre, Delhi, (Hereinafter Referred To As The Assessing Officer, “Ao” In Short) Passed U/S.143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 (Act) In Relation To Assessment Year 2017-18. 2. The Assessee In Engaged In The Business Of Providing Software Development Services (Swd Services), To Its Wholly Owned Holding Company. In Terms Of The Provisions Of Sec.92-A Of The Act, The Assessee

For Appellant: Shri. Chavali Narayanan, CAFor Respondent: Capt. Pradeep Arya, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C(13)Section 92Section 92ASection 92B(1)Section 92CSection 92C(2)Section 92F

Vasudevan, Vice President This appeal by the Assessee is directed against the Final Order of Assessment dated 29.03.2022 of National Faceless Assessment Centre, Delhi, (hereinafter referred to as the Assessing Officer, “AO” in short) passed u/s.143(3) read with Section 144C(13) of the Income

Essilor India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 448/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Oct 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 448/Bang/2022 Assessment Year : 2017-18 M/S. Essilor India Pvt. Ltd., 10Th Floor, Prestige The Deputy Trade Tower, Commissioner Of 46, Palace Road, Income Tax, High Grounds Circle – 2(1)(1), Sampangi Rama Bangalore. Vs. Nagar, Bengaluru – 560 001. Pan: Aaace4623J Appellant Respondent Assessee By : Shri Chavali Narayan, Ca : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 27-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 31/03/2022 Passed By The National Faceless Assessment Centre, Delhi For A.Y. 2017-18 On Following Grounds Of Appeal:

For Appellant: Shri Chavali Narayan, CA

Section 142(1)Section 143(2)Section 14ASection 92Section 92C

Pronouncement : 21-10-2022 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal is filed by assessee against order dated 31/03/2022 passed by the National Faceless Assessment Centre, Delhi for A.Y. 2017-18 on following grounds of appeal: Page 2 of 13 IT(TP)A No. 448/Bang/2022 Page