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“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
97
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
88
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
55
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
53
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
50
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
50
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

Lalitha Kuchibhatla, Chittoor vs. ITO, Ward-1(1), Tirupati

In the result, the appeal of the assessee is allowed in terms of our above observation

ITA 1543/HYD/2025[2016-17]Status: DisposedITAT Hyderabad16 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1543/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Smt. Lalitha Kuchibhatla Vs. Income Tax Officer Chittoor Ward 1(1) Pan:Axdpk2304D Tirupati (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate S. Sandhya राज" व "ारा/Revenue By: Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 08/01/2026 घोषणा की तारीख/Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Smt. Lalitha Kuchibhatla (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 26.08.2025 For The A.Y 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate S. SandhyaFor Respondent: Shri Madhukar AVES, Sr. DR
Section 144BSection 145Section 147Section 148Section 148ASection 151A(1)

well as the order passed under section 148A(d) of the Act were by the Jurisdictional Assessing Officer (“JAO”) instead of the Faceless Assessing Officer (“FAO”), which is contrary to the scheme of Page 3 of 21 ITA No 1543 of 2025 Lalitha Kuchibhatla faceless reassessment introduced by the CBDT ... mandates that with effect from 29.03.2022, all notices under section 148 of the Act must be issued through the Faceless Assessment Unit. Relying on various decisions of the Coordinate Benches of the Tribunal and Hon’ble High Courts, the Ld. AR argued that when a notice is issued

Sukesini Kumili, Hyderabad vs. ITO, Ward-15(1), Hyderabad

In the result, the appeals of the assessee in ITA no

ITA 1539/HYD/2025[2016-17]Status: DisposedITAT Hyderabad16 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaappeal In Ita Nos. Assessee Revenue A.Ys 1536 To 1539/ Hyd/2025 Sukesini Kumili, Hyderabad Pan:Ckmpk5466J Income Tax Officer Ward 15(1), Hyderabad 2015-16 & 2016-17 निर्धारिती द्वारा /Assessee By: Advocate Shri S. Rama Rao राजस्व द्वारा / Revenue By:: || Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख/Date Of Hearing: | 07/01/2016 घोषणा की तारीख / Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Four Appeals Are Filed By Smt. Sukesini Kumili ("The Assessee") Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) For The A.Ys 2015-16 & 2016-17, All Dated 16.07.2025. Since Inter-Related Issues Are Involved In All These Four Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Advocate Shri S. Rama Rao
Section 115BSection 144Section 147Section 148Section 148ASection 149Section 151A(1)Section 153

well as the order passed under section 148A(d) of the Act were by the Jurisdictional Assessing Officer (“JAO”) instead of the Faceless Assessing Officer (“FAO”), which is contrary to the scheme of faceless reassessment introduced by the CBDT. In this regards, the Ld. AR invited our attention ... mandates that with effect from 29.03.2022, all notices under section 148 of the Act must be issued through the Faceless Assessment Unit. Relying on various decisions of the Coordinate Benches of the Tribunal and Hon'ble High Courts, the Ld. AR argued that when a notice is issued

Sukesini Kumili, Hyderabad vs. ITO, Ward-15(1), Hyderabad

In the result, the appeals of the assessee in ITA no

ITA 1538/HYD/2025[2016-17]Status: DisposedITAT Hyderabad16 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Ys Nos. 1536 To 1539/ Sukesini Kumili, Income Tax Officer 2015-16 & Hyd/2025 Hyderabad Ward 15(1),Hyderabad 2016-17 Pan:Ckmpk5466J िनधा""रती "ारा/Assessee By: Advocate Shri S. Rama Rao राज" व "ारा/Revenue By:: Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 07/01/2016 घोषणा की तारीख/Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Four Appeals Are Filed By Smt. Sukesini Kumili (“The Assessee”) Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) For The A.Ys 2015-16 & 2016-17, All Dated 16.07.2025. Since Inter-Related Issues Are Involved In All These Four Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Advocate Shri S. Rama RaoFor Respondent: : Shri Madhukar AVES, Sr. DR
Section 144Section 147Section 148Section 148ASection 151A(1)

well as the order passed under section 148A(d) of the Act were by the Jurisdictional Assessing Officer (“JAO”) instead of the Faceless Assessing Officer (“FAO”), which is contrary to the scheme of faceless reassessment introduced by the CBDT. In this regards, the Ld. AR invited our attention ... mandates that with effect from 29.03.2022, all notices under section 148 of the Act must be issued through the Faceless Assessment Unit. Relying on various decisions of the Coordinate Benches of the Tribunal and Hon’ble High Courts, the Ld. AR argued that when a notice is issued

Sukesini Kumili, Hyderabad vs. ITO, Ward-15(1), Hyderabad

In the result, the appeals of the assessee in ITA no

ITA 1537/HYD/2025[2015-16]Status: DisposedITAT Hyderabad16 Jan 2026AY 2015-16

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Ys Nos. 1536 To 1539/ Sukesini Kumili, Income Tax Officer 2015-16 & Hyd/2025 Hyderabad Ward 15(1),Hyderabad 2016-17 Pan:Ckmpk5466J िनधा""रती "ारा/Assessee By: Advocate Shri S. Rama Rao राज" व "ारा/Revenue By:: Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 07/01/2016 घोषणा की तारीख/Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Four Appeals Are Filed By Smt. Sukesini Kumili (“The Assessee”) Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) For The A.Ys 2015-16 & 2016-17, All Dated 16.07.2025. Since Inter-Related Issues Are Involved In All These Four Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Advocate Shri S. Rama RaoFor Respondent: : Shri Madhukar AVES, Sr. DR
Section 144Section 147Section 148Section 148ASection 151A(1)

well as the order passed under section 148A(d) of the Act were by the Jurisdictional Assessing Officer (“JAO”) instead of the Faceless Assessing Officer (“FAO”), which is contrary to the scheme of faceless reassessment introduced by the CBDT. In this regards, the Ld. AR invited our attention ... mandates that with effect from 29.03.2022, all notices under section 148 of the Act must be issued through the Faceless Assessment Unit. Relying on various decisions of the Coordinate Benches of the Tribunal and Hon’ble High Courts, the Ld. AR argued that when a notice is issued

Sukesini Kumili, Hyderabad vs. ITO, Ward-15(1), Hyderabad

In the result, the appeals of the assessee in ITA no

ITA 1536/HYD/2025[2015-16]Status: DisposedITAT Hyderabad16 Jan 2026AY 2015-16

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaappeal In Ita Assessee Revenue A.Ys Nos. 1536 To 1539/ Sukesini Kumili, Income Tax Officer 2015-16 & Hyd/2025 Hyderabad Ward 15(1),Hyderabad 2016-17 Pan:Ckmpk5466J िनधा""रती "ारा/Assessee By: Advocate Shri S. Rama Rao राज" व "ारा/Revenue By:: Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 07/01/2016 घोषणा की तारीख/Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Four Appeals Are Filed By Smt. Sukesini Kumili (“The Assessee”) Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) For The A.Ys 2015-16 & 2016-17, All Dated 16.07.2025. Since Inter-Related Issues Are Involved In All These Four Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Advocate Shri S. Rama RaoFor Respondent: : Shri Madhukar AVES, Sr. DR
Section 144Section 147Section 148Section 148ASection 151A(1)

well as the order passed under section 148A(d) of the Act were by the Jurisdictional Assessing Officer (“JAO”) instead of the Faceless Assessing Officer (“FAO”), which is contrary to the scheme of faceless reassessment introduced by the CBDT. In this regards, the Ld. AR invited our attention ... mandates that with effect from 29.03.2022, all notices under section 148 of the Act must be issued through the Faceless Assessment Unit. Relying on various decisions of the Coordinate Benches of the Tribunal and Hon’ble High Courts, the Ld. AR argued that when a notice is issued