“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

Biocon Biologics Limited (Formerly Known As Biocon Biologics India Limited) (Successor to Biocon Research Limited), Bangalore vs. The Deputy Commissioner of Income Tax, Circle-1(1)(1), Bangalore

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

ITA 299/BANG/2022[2017-18]Status: DisposedITAT Bangalore13 Sept 2022AY 2017-18

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm It(Tp)A No.299/Bang/2022 : Asst.Year 2017-2018 M/S.Biocon Biologics Limited The Deputy Commissioner Of (Formerly Known As Biocon Income-Tax, Circle 1(1)(1) V. Biologics India Limited) Bengaluru. Ground Floor, Tower 3, Semicon Park, Hosur Road, Electronics City S.O. Bangalore South – 560 100. Pan : Aagcb7796M. (Appellant) (Respondent) Appellant By : Sri.Padam Chand Khincha, Ca Respondent By : Sri.Manjunath Karkihalli, Cit-Dr Date Of Pronouncement : 13.09.2022 Date Of Hearing : 06.09.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 26.02.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2017-2018. 2. The Brief Facts Of The Case Are As Follows: The Assessee, Namely, Biocon Biologics Limited [Successor. To Biocon Research Limited With Appointed Date 01.04.2019] Is Engaged In The Carrying Out Research & Development ("R & D") Of Drugs & Drug Delivery Systems. For The Relevant Assessment Year ("Ay") 2017-18, The Return Of Income Was Filed On 30.11.2017, Declaring `Nil’ Income Under The Normal Provisions Of The I.T.Act & Book Losses As 2 It(Tp)A No.299/Bang/2022. M/S.Biocon Biologics Limited Per The Provisions Of Section 115Jb Of The I.T.Act. After Considering The Taxes Deducted At Source, The Assessee Had Claimed Refund Of Inr 4,68,29,020 In The Return Of Income.

For Appellant: Sri.Padam Chand Khincha, CAFor Respondent: Sri.Manjunath Karkihalli, CIT-DR

Section 115JSection 143(2)Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 92C

respectfully craves leave to prefer an appeal against the order passed by the Additional/Joint / Deputy / Assistant Commissioner of Income Tax / Income Tax Officer, National Faceless Assessment Centre, Delhi ("Ld. AO"), dated 26 February 2022 (received by the Appellant on 26 February 2022), under section 143(3) read with section 144C ... variations as mandated by section 144B(1)(xvi) of the Act and passing the impugned Order, which is in violation of proceedings under the Faceless Assessment Scheme and in violation of the principles of natural justice. 5.2. not providing any reasons for disallowing the foreign exchange loss and without providing

M/S. G Corp Spaces Private Limited, Bangalore vs. The Assistant Commissioner of Income Tax, Circle- 3(1)(2), Bangalore

Appeal is allowed for statistical purposes

ITA 198/BANG/2022[2017-18]Status: DisposedITAT Bangalore13 Sept 2022AY 2017-18

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

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(3)

Pronouncement : 13.09.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is against the final assessment order passed by National Faceless Assessment Centre u/s. 143(3) r.w.s. 144C(13) of the IT Act dated 28.1.2022 for the assessment year 2017-18. 2. The only issue arising

Sree Subha Sales, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by assessee stands allowed for statistical purposes

ITA 682/BANG/2022[2018-19]Status: DisposedITAT Bangalore12 Sept 2022AY 2018-19

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2018-19

For Respondent: Shri B.R. Sudheendra

Ld.AO. 3. We refer to the decision of Hon'ble Karnataka High Court in case of Sri. Pichila Jayachandra Reddy vs. National Faceless Assessment Centre in W.P. No. 9669/2022(T-IT) by order dated 07/06/2022 wherein the Hon’ble High Court observed as under: “5. It is clear from ... India vs. ACIT reported in [2022] 140 taxmann.com 41  Decision of Hon’ble Madras High Court in case of Ramco Cements Ltd. vs. National Faceless Assessment Centre reported in [2022] 139 taxmann.com 81 5. We note that assessee was denied the opportunity of being heard, and the NFAC simply proceeded

Toyota Tsusho India Private Limited, Ramanagara vs. The Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal is allowed in favour of the assessee

ITA 175/BANG/2022[2017-18]Status: DisposedITAT Bangalore09 Sept 2022AY 2017-18

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Darpan Kriplani, CAFor Respondent: Shri V S Chakrapani, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 14A

Date of Pronouncement : 09.09.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is against the order of the National Faceless Assessement Centre, Delhi [NFAC] passed u/s.143(3) r.w.s.144(13) of the Income Tax Act 1962 (the Act) dated 11.2.2022 for the assessment year ... which was disposed on 18.01.2022 giving directions to TPO. The disallowance u/s 14A was upheld by the DRP. Final assessment Order was passed by Faceless Assessment Unit on 11.02.2022. Based on the directions of DRP, TPO passed an OGE dated 15.2.2022 arriving at total adjustment

Amc Cookware (India) Private Limited, Bangalore vs. Income Tax Officer, Ward-1(1)(1), Bangalore

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

ITA 429/BANG/2022[2017-18]Status: DisposedITAT Bangalore07 Sept 2022AY 2017-18

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.429/Bang/2022 Assessment Year : 2017-18 M/S. Amc Cookware (India) Private Limited, Vs. Ito, No.1180, 12Th B Main, 1St Cross, Hal 2Nd Ward – 1(1)(1), Stage, Indira Nagar, Bengaluru. Bengaluru – 560 008. Pan : Aacca 4970 G Appellant Respondent Assessee By : Shri. K. P. Srinivas, Ca Revenue By : Shri. V. S. Chakrapani, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 01.09.2022 Date Of Pronouncement : 07.09.2022 O R D E R Per N. V. Vasudevan: This Is An Appeal By The Assessee Against The Final Order Of Assessment Dated 30.03.2022 Passed By The Ito, Ward – 1(1)(1) Of National Faceless Assessment Centre, Delhi, Passed Under Section 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1962 (Hereinafter Called ‘The Act’) In Relation To Assessment Year 2017-18. 2. The Only Dispute Raised By The Assessee In This Appeal Is As To Whether The Revenue Authorities Were Justified In Determining The Shortfall In Arm’S Length Price (Alp) Of An International Transaction At Rs.2,37,87,122/- & It(Tp)A No.429/Bang/2022 Page 2 Of 8

For Appellant: Shri. K. P. Srinivas, CAFor Respondent: Shri. V. S. Chakrapani, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 92

appeal by the assessee against the final Order of Assessment dated 30.03.2022 passed by the ITO, Ward – 1(1)(1) of National Faceless Assessment Centre, Delhi, passed under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1962 (hereinafter called ‘the Act’) in relation to Assessment

Cerner Healthcare Solutions India Private Limited (Earlier Known As Cerner India Health Services Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, the appeal by the assessee is allowed

ITA 274/BANG/2022[2017-18]Status: DisposedITAT Bangalore06 Sept 2022AY 2017-18

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Sumeet Khurana, CAFor Respondent: Shri V S Chakrapani, CIT(DR)(ITAT), Bengaluru

Section 37Section 43B

Date of hearing : 30.08.2022 Date of Pronouncement : 06.09.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is by the National Faceless Assessment Centre, Delhi [NFAC], Delhi passed us/. 143(3) r.w.s. 144C(3) r.w.s. 144B of the Income-tax Act, 1961 [the Act] dated

Rakyan Beverages Private Limited, Raigarh vs. ACIT 5(3)(1), Mumbai

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

ITA 120/MUM/2022[2018-19]Status: DisposedITAT Mumbai24 Aug 2022AY 2018-19

For Appellant: Shri J. D. Mistry & MadhurFor Respondent: Shri Prakash Mane (DR)

Section 68

attractive investment destination, have great faith and confidence in the justness of the decision making process which has serious civil consequences. The Faceless Assessment Scheme and the Taxpayer' Charter which was introduced on 13-8-2020 was to ease the compliance burden, to increase fairness and objectivity in the assessment ... clearly failed in their duties set out in their respective Schemes/Charters. 22 A.Y. 2018-19 Raw Pressery Pvt. Ltd. 23. On perusal of the Faceless Assessment Scheme, 2019, it is noted that the Assessment Unit of the NFAC could very well have referred the enquiry/verification into the foreign investors

M/S. Rittal India Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 392/BANG/2022[2017-18]Status: DisposedITAT Bangalore24 Aug 2022AY 2017-18

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

For Appellant: Shri Ramasubramaniyan, CAFor Respondent: Shri Bijoy Kumar Panda, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 37Section 92Section 92C

Date of Pronouncement : 24.08.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is against the assessment order of the National Faceless Assessment Centre, Delhi passed u/s. 143(3) r.w.s. 144C(13) of the Income-tax Act, 1961 [the Act] dated 22.3.2022 for the assessment year

Capita India Pvt Limited (Capita India), Mumbai vs. Nafc Delhi, Delhi

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

ITA 732/MUM/2022[2017-18]Status: DisposedITAT Mumbai18 Aug 2022AY 2017-18

Section 143(3)Section 14A

B.R.Baskaran (AM) :- The assessee has filed this appeal challenging the final assessment order dated 25-02-2022 passed by the assessing officer, National faceless assessment centre, Delhi for assessment year 2017-18 u/s 143(3) r.w.s 144C(13) r.w.s 144B of the Act in pursuance of directions given

Mukesh Shivgan Patel, Mumbai vs. Income Tax Officer National Faceless Assessment Centre, Delhi

In the result, the appeal is allowed for statistical purposes in the terms indicated above

ITA 1811/MUM/2022[2018-19]Status: DisposedITAT Mumbai18 Aug 2022AY 2018-19

Section 143(3)Section 56(2)(x)

Mukesh Shivgan Patel ……………...………… Appellant B-2, Himalaya Darshan, Din Dayal Road, Anand Nagar, Dombivali (W)- 421 201 [PAN: ALFPP9824K] Vs. Income Tax Officer, National Faceless Assessment Centre, Delhi ………………….…… Respondent Appearances by: None for the appellant Tejinder Pal Singh for the respondent Date of concluding the hearing : August 10, 2022 Date

Hemson Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 2(1)(2), Mumbai

In the result, all the appeals are allowed in the terms indicated above

ITA 1898/MUM/2022[2013-2014]Status: DisposedITAT Mumbai10 Aug 2022AY 2013-2014

Section 143(1)Section 36(1)(va)Section 44A

Hemson Priate Limited ……………...………… Appellant 60 Mistry Industrial Complex, MIDC Cross, Road-A, Andheri (E) Mumbai 400 093 [PAN: AAACH5549J] Vs. National Faceless Assessment Centre Delhi ………………….…… Respondent Appearances by: None for the appellant Tejinder Pal Singh for the respondent Date of concluding the hearing : August 10, 2022 Date of pronouncement

Hemson Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 2(1)(1), Mumbai

In the result, all the appeals are allowed in the terms indicated above

ITA 1897/MUM/2022[2012-13]Status: DisposedITAT Mumbai10 Aug 2022AY 2012-13

Section 143(1)Section 36(1)(va)Section 44A

M/S. Logicon Alternate Fuels Pvt. Ltd, Mumbai vs. Dy.Commissioner of Income Tax, CPC, Bangalore

In the result, all the appeals are allowed in the terms indicated above

ITA 1842/MUM/2022[2018-19]Status: HeardITAT Mumbai10 Aug 2022AY 2018-19

Section 143(1)Section 36(1)(va)Section 44A

Novo Nordisk India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-5(1)(1), Bangalore

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

ITA 611/BANG/2021[2016-17]Status: DisposedITAT Bangalore10 Aug 2022AY 2016-17

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

For Appellant: Smt. Shreya Loyalka, CAFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 194HSection 40

Additional/Joint/ Plot No.32, 47-50, EPIP Area, Deputy/Assistant Whitefield, Commissioner of Income Bangalore- 560 066. Tax/ITO, PAN: AAACN 7425M National Faceless Assessment Centre, Delhi. APPELLANT RESPONDENT Appellant by : Smt. Shreya Loyalka, CA Respondent by : Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru. Date of hearing : 04.08.2022 Date of Pronouncement ... Padmavathy S., Accountant Member This appeal by the assessee is against the order of the AO, National Faceless Assessment Centre, Delhi passed u/s. 143(3) r.w.s. 144C(13) dated 20.9.2021 for the assessment year 2016-17. 2. The assessee raised grounds pertaining to the following issues:- Disallowance of discount expenses

Mersen India Private Limited, Bangalore vs. Joint Commissioner of Income Tax (OSD), Circle-4(1)(2), Bangalore

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 381/BANG/2022[2017-18]Status: DisposedITAT Bangalore08 Aug 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 381/Bang/2022 Assessment Year : 2017-18 M/S. Mersen India Pvt. The Joint Ltd., Commissioner Of No. 5, Bommasandra Income Tax (Osd), Industrial Area, Circle – 4 (1)(2), Bangalore – 560 099. Vs. Bangalore. Pan: Aaace3191K Appellant Respondent Assessee By : Smt. Ramya Nayak, Ca : Shri Sumer Singh Meena, Revenue By Cit Dr-1 Date Of Hearing : 04-08-2022 Date Of Pronouncement : 08-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Assessment Order Dated 22/03/2022 By The National Faceless Assessment Centre, Delhi For A.Y. 2017-18 On Following Grounds Of Appeal: “The Grounds Mentioned Hereinafter Are Without Prejudice To One Another. Transfer Pricing 1. The Transfer Pricing Officer ("Tpo"), The Assessing Officer ("Ao") & The Dispute Resolution Panel, Bangalore ("Drp") Have Grossly Erred In Law & Facts Of The Case In Determining The Arm'S Length Price ("Alp") Of The Human Resource Services As Nil. 2. The Learned Tpo/ Ao/Drp Has Erred In Not Considered The Fact That The Human Resource Services Is As Per The Arm'S Length Price Adopting The Transaction Net Margin Method (" Tnmm")

For Appellant: Smt. Ramya Nayak, CA

Pronouncement : 08-08-2022 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal is filed by assessee against assessment order dated 22/03/2022 by the National Faceless Assessment Centre, Delhi for A.Y. 2017-18 on following grounds of appeal: “The grounds mentioned hereinafter are without prejudice to one another. Transfer Pricing

Ksb Ltd. (Earlier Known As "Ksb Pumps Ltd."), Pune vs. The Dy CIT, National Faceless Assessment Centre (Nafac) Delhi, Mumbai

ITA 1210/MUM/2021[2016-17]Status: DisposedITAT Mumbai29 Jul 2022AY 2016-17

Bench: Shri Baskaran Br & Shri Kuldip Singhassessment Year: 2016-17

For Appellant: Shri Nikhil Tiwari, A.RFor Respondent: Shri Sambit Mishra, D.R

Section 115JSection 143(3)Section 144BSection 144C(13)Section 253(1)(d)Section 271(1)(c)Section 274Section 92C

dated 22 April 2021 (received by the Appellant on 22 April 2021) passed by the Additional / Joint / Deputy / Assistant Commissioner of Income Tax, National Faceless Assessment Centre ('NaFAC'), Delhi (hereinafter referred to as the 'learned 'AO') under section 143(3) read with section 144C(13) read with section 144B

M/S Quicklogic Software (India) Pvt. Ltd., Bangalore vs. Deputy Commissioner of Income-Tax, Circle-3(1)(1), Bengaluru

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

ITA 181/BANG/2022[2017-18]Status: DisposedITAT Bangalore27 Jul 2022AY 2017-18

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 181/Bang/2022 Assessment Year : 2017-18 M/S. Quicklogic Software (India) Pvt. Ltd., No. 10 Brindavan, The Deputy 3Rd Floor, Commissioner Of Yashoda Nagar Main Income Tax, Road, Circle 3(1)(1), Jakkur Plantation, Vs. Bangalore. Bengaluru – 560 064. Pan: Aaacq0656P Appellant Respondent Assessee By : Shri Mahaveer C Jain, Ca : Shri Sumer Singh Meena Cit Revenue By Dr Date Of Hearing : 12-07-2022 Date Of Pronouncement : 27-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 25/01/2022 By The National Faceless Assessment Centre For A.Y. 2017-18 On Following Revised Grounds Of Appeal:

For Appellant: Shri Mahaveer C Jain, CA

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

Pronouncement : 27-07-2022 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal is filed by assessee against order dated 25/01/2022 by the National Faceless Assessment Centre for A.Y. 2017-18 on following revised grounds of appeal: Page 2 IT(TP)A No. 181/Bang/2022 Page 3 IT(TP)A No. 181/Bang/2022

Cerner Healthcare Solutions India Private Limited (Erstwhile Cerner Healthcare Solution Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

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

ITA 171/BANG/2022[2017-18]Status: DisposedITAT Bangalore27 Jul 2022AY 2017-18

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

For Appellant: Shri Sumit Khurana, CAFor Respondent: Shri Srinivas T. Bidari, CIT(DR)(ITAT), Bengaluru

Section 115JSection 143(3)Section 154Section 270ASection 37Section 40

Pronouncement : 27.07.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is against the final assessment order passed by the National Faceless Assessment Centre (NFAC), Delhi u/s. 143(3) r.w.s. 144(C13) of the Income Tax Act, 1961 (the Act) dated 13.01.2022 for the assessment year

M/S. Altisource Business Solutions Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bangalore

In the result, the appeal is allowed in favour of the assessee

ITA 183/BANG/2022[2017-18]Status: DisposedITAT Bangalore25 Jul 2022AY 2017-18

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

For Appellant: Shri Nitin G. Inamdar, CAFor Respondent: Shri Srinivas T. Bidari, CIT(DR)(ITAT), Bengaluru

Section 115JSection 143(2)Section 143(3)

Pronouncement : 25.07.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is against the final assessment order passed by the National Faceless Assessment Centre (NFAC) u/s. 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (the Act) dated

Prashant Vijay Kale, Thane vs. CPC, Income Tax Dept., Bengaluru

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

ITA 2100/MUM/2021[2018-19]Status: DisposedITAT Mumbai22 Jul 2022AY 2018-19

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm National Faceless Appeal Prashant Vijay Kale Center 47-403, Swastik Residency, Centralized Processing Near Muchhala College, Vs. Gb Road Kavesar, Center, Income Tax Thane, Mumbai-400 615 Department, Bengaluru (Respondent) (Appellant) Pan No. Adapk8367M Assessee By : Mr. Rajan Vora, Adv Revenue By : Mr. Nihar Rajan Samal, Sr. Ar Date Of Hearing: 21.06.2022 Date Of Pronouncement : 22.07.2022

For Appellant: Mr. Rajan Vora, AdvFor Respondent: Mr. Nihar Rajan Samal, Sr. AR

Section 143(1)Section 143(3)Section 234Section 234ASection 234BSection 234FSection 4(2)Section 6(1)Section 90

assessee made a detailed written submission wherein in paragraph number 5 the complete facts are mentioned which is also been reproduced by the National faceless assessment centre but did not consider that assessee has also filed original return of income. Undisputedly along with the original return of income form number