“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

Adhimoolam Varadham Murugan, Tiruvallur vs. ITO, Ncw-5(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 2755/CHNY/2025[2015-16]Status: DisposedITAT Chennai07 Jan 2026AY 2015-16

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2755/Chny/2025 िनधा%रण वष% /Assessment Year: 2015-16

For Appellant: Mr. H.Yeshwanth Kumar, C.A *+For Respondent: Ms. Latchana, CIT

Section 147Section 148Section 148ASection 250Section 69A

Jurisdictional Assessing Officer (JAO) issues the notice and it is not mandatory Adhimoolam Varadham Murugan :- 3 -: that it should be issued by the Faceless Assessment Officer (FAO). Another learned Single Judge in order dated 21.04.2025 in WP No.22402 of 2024 and batch cases, followed what was held by the Bombay

Shanmugam Palanisamy, Keerambur vs. Income Tax Officer, Ward 2, Namakkal

In the result, appeal filed by the assessee is allowed

ITA 2701/CHNY/2025[2020-21]Status: DisposedITAT Chennai07 Jan 2026AY 2020-21

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.P.M.Kathir, AdvocateFor Respondent: Mr. K.Ilaiyaraja, Addl.CIT

Section 144BSection 147Section 148Section 148ASection 151Section 151A

Judge was pleased to dismiss the petition on the ground that even if the notice has been issued by Jurisdictional Assessment Officer and not Faceless Assessment Officer, the notice issued under Section 148A/148 of the Income Tax Act will be valid. 3. Ms.Vardhini Karthik submitted that this Court ... judgment of the Bombay High Court in Hexaware Technologies Limited v. Assistant Commissioner of Income Tax', that notice that has to be issued by Faceless Assessment Officer has to be issued Faceless Assessment Office and if issued by Jurisdictional Assessment Officer, the same is not valid. 4. Ms.Premalatha, who takes

Palanisamy Srilatha, Salem vs. ITO, Ward-196), Salem

In the result, appeal filed by the assessee is allowed

ITA 2027/CHNY/2025[2015-16]Status: DisposedITAT Chennai07 Jan 2026AY 2015-16

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.S Sridhar, Adv (Erode)For Respondent: Ms. R Anitha, Addl.CIT

Section 144BSection 147Section 148Section 148ASection 151Section 151A

Income Tax Officer, Delhi vs. Himanshu Goel, Mayur Vihar Delhi

In the result, the appeal filed by the Department of Revenue is dismissed

ITA 5232/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 143(2)Section 250Section 68Section 69A

KUMAR, JUDICIAL MEMBER: The appeal filed by the Department of Revenue is against order dated 02.07.2025 of Learned Commissioner of Income Tax (Appeals)/National Faceless Assessment Centre (NFAC), Delhi (hereinafter referred to as “Ld. CIT(A)") under Section 250 of the Income Tax Act, 1961 (hereinafter referred

M/S Jhs Svendgaard Laboratories Ltd., New Delhi vs. DCIT CC-31, New Delhi

In the result, Appeal of the Assessee is allowed

ITA 3454/DEL/2025[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.M/S Jhs Svendgaard Vs. Dcit Laboratories Ltd. B1/E-23, Central Circle-31, New Mohan Cooperative Delhi Tuhglakabad, Badarpur, New Delhi New Delhi Pan: Aabcj5766G Appellant Respondent Assessee By Sh. Gaurav Jain, Adv & Sh. Tarun Chanana, Adv Revenue By Ms.Amisha S. Gupt, Cit (Dr) Date Of Hearing 09/10/2025 Date Of Pronouncement 07/01/2026 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-30, New Delhi [‘Ld. Cit(A)’

Section 147Section 148Section 151ASection 37

violation of provisions of section 151A of the Act, read with Notification No. 18/2022 dated 29.03.2022, which should have been issued by National Faceless Assessment Centre under e-Assessment of Income Escaping Assessment Scheme, 2022. 5. That the CIT(A) has erred on facts and in law in confirming ... violation of provisions of section 151A of the Act, read with Notification No. 18/2022 dated 29.03.2022, which should have been issued by National Faceless Assessment Centre under e-Assessment of Income Escaping Assessment Scheme, 2022’. However, the Ld. Assessee's Representative fairly submitted that the Jurisdictional High Court

Giesecke and Devrient India Pvt Ltd., Gurgaon vs. ACIT (OSD), New Delhi

In the result, assessee’s appeal in ITA No

ITA 1428/DEL/2022[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Ms. Madhumita Roy & Smt. Renu Jauhriassessment Year: 2018-19

Section 119Section 143(3)Section 144BSection 144B(8)Section 144C(13)Section 144C(5)

That the impugned Final Assessment order dated 30.05.2022 is non-est, having being passed by the ACIT(OSD) as opposed to the National Faceless Assessment Centre ("NFAC") which had validly assumed jurisdiction over the Assessee. 3 ITA No. 1428/Del/2022 & SA No. 166/Del/2022 9. That on the facts of the case ... affirmed by the Bombay High Court in the aforenoted paragraphs of Vodafone Idea and in Shell India Markets (P.) Ltd. v. Addt. CIT. National Faceless Assessment Centre [2022] 139 taxmann.com 335/443 ITR 366 (Bom)/Judgment dated 14 February 2022 in WP No. 3298/2021. The relevant paragraph of the decision

Income Tax Offier, Ward 6(1), Ludhiana vs. Balpreet Singh, Ludhiana

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

ITA 1022/CHANDI/2025[2016]Status: DisposedITAT Chandigarh06 Jan 2026

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Balpreet Singh, AssesseeFor Respondent: Shri Manav Bansal, CIT, DR

Section 133(6)Section 142(1)Section 143(1)(a)Section 144Section 148Section 151Section 251Section 69A

assessee failed to file the return of income within the stipulated period of 30 days. 3.1 Thereafter, the case was assigned to the Faceless Assessment Unit on 11.11.2021. During the course of reassessment proceedings, the jurisdictional Assessing Officer as well as the FAU issued several statutory notices under section

Arundhati Dnyandeo Kalane, Ahilyanagar vs. ITO, Ward-1, Ahilyanagar

In the result, the appeal filed by the assessee is partly allowed as per the terms indicated above

ITA 623/PUN/2025[2013-14]Status: DisposedITAT Pune06 Jan 2026AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.623/Pun/2025 Assessment Year : 2013-14

For Appellant: Shri Prasad BhandariFor Respondent: Shri Bharat Andhale

Section 147Section 250Section 69

contents of said Affidavit reads as under: “2. That for the A.Y. 2013-14, the learned Assessing Officer of Income Tax. National Faceless Assessment Centre vide his order dt. 17.03.2022 made addition of Rs.73,62,600 u/s.69 of the I.T. Act 1961 for the reasons as mentioned in the said

Binny Kohli, Pune vs. ITO, Ward-14(1), Pune

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 2650/PUN/2025[2018-19]Status: DisposedITAT Pune06 Jan 2026AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2648 To 2650/Pun/2025 Assessment Years : 2016-17, 2017-18 & 2018-19

For Appellant: Shri Priyesh KhiradFor Respondent: Shri Manish Sinha

Section 147Section 156Section 246A

being a housewife. 6. That, the Assessee disagrees with the Assessment Order and Notice of Demand as passed by the Income Tax Officer, National Faceless Assessment Centre, Delhi, and willing to file an Appeal against the said Order. Hence, it is humbly prayed to your honor to consider the matter

Binny Kohli, Pune vs. ITO, Ward-14(1), Pune

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 2649/PUN/2025[2017-18]Status: DisposedITAT Pune06 Jan 2026AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2648 To 2650/Pun/2025 Assessment Years : 2016-17, 2017-18 & 2018-19

For Appellant: Shri Priyesh KhiradFor Respondent: Shri Manish Sinha

Section 147Section 156Section 246A

Binny Kohli, Pune vs. ITO, Ward-14(1), Pune

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 2648/PUN/2025[2016-17]Status: DisposedITAT Pune06 Jan 2026AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2648 To 2650/Pun/2025 Assessment Years : 2016-17, 2017-18 & 2018-19

For Appellant: Shri Priyesh KhiradFor Respondent: Shri Manish Sinha

Section 147Section 156Section 246A

George Molakal Mathew, Pune vs. ITO International Tax Ward-3, Pune

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

ITA 2236/PUN/2025[2016-17]Status: DisposedITAT Pune05 Jan 2026AY 2016-17

Bench: or during the hearing of the Appeal.”

For Appellant: Shri Kanchun Kaushal (Virtual)For Respondent: Shri Umesh Phade

Section 142(1)Section 147Section 148Section 194ASection 3

challenged the validity of reopening of the assessment u/s 147 of the IT Act and also challenged passing of the assessment order by National Faceless Assessment Centre, Delhi, before Ld. CIT(A)/NFAC, however, Ld. CIT(A)/NFAC has not adjudicated these legal grounds. 7. Considering the totality

Processia Plm Private Limited, Pune vs. National Faceless Assessment Center, Delhi

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

ITA 2007/PUN/2025[2018-19]Status: DisposedITAT Pune05 Jan 2026AY 2018-19

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2007/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Processia Plm Private Vs. Income Tax Department, Limited, National E-Assessment First Floor, Office No.102, Centre, Delhi. Amar Apex Building, Amar Apex Condominium, Baner, Pune-411045. Pan : Aaact6811H Appellant Respondent Assessee By : Ms. Nidhi Agarwal (Virtual) Revenue By : Shri Harshit Bari Date Of Hearing : 17.12.2025 Date Of Pronouncement : 05.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 12.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “Ground No. 1: On The Facts & In The Circumstances Of The Case & In Law, The Order Under Section 250 Of The Income-Tax Act,1961 ('The Act') Passed By The Learned Commissioner Of Income Tax (Appeals) ['Ld. Cit(A)'] On 12 June 2025 Is Bad In Law.

For Appellant: Ms. Nidhi Agarwal (Virtual)For Respondent: Shri Harshit Bari

Section 143(2)Section 143(3)Section 144BSection 244ASection 250

erred in upholding the disallowance of credit of taxes deducted at source amounting to INR 15,18,619 made by the National Faceless Assessment Centre, Delhi ('Learned AO') in the assessment order dated 17 April 2021 passed under section 143(3) read with section 144B of the Act. Ground

Assistant Commissioner of Income Tax, Tirunelveli vs. Srinivasagam Selvamathan, Tuticorin

In the result, appeal filed by the revenue is dismissed

ITA 2654/CHNY/2025[2013]Status: DisposedITAT Chennai05 Jan 2026

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr. SrinivasagamFor Respondent: Mr.Shiva Srinivas, CIT

Section 144BSection 147Section 148Section 148ASection 151Section 151A

Marks and Spencer (India) Private Limited, Gurgaon vs. ACIT, Circle 1(1), Gurgaon

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

ITA 1937/DEL/2022[2018-19]Status: DisposedITAT Delhi05 Jan 2026AY 2018-19

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Dharm Veer Singh, CIT DR

Section 143(3)Section 144C(13)Section 144C(5)Section 92C

income of the assessee and referred pages 114& 115of Appeal set for relevant extract of the TP order. 10. Subsequently, the Assessing Officer, National Faceless Assessment Centre (‘AO’) proceeded to pass draft assessment order by considering the adjustments proposed by the TPO and referred pages 90 to 93 of Appeal ... before us that it is pertinent to mention that the Final Assessment Order was passed by the Jurisdictional Assessing Officer (‘JAO’) instead of National Faceless Assessment Centre (‘NFAC’). As per section 144Bof the Act, all assessment under section 143 is required to be made in a faceless manner

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

ITA 3048/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Jan 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:3046, 3047 & 3048/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16, 2016-17 & 2017-18 Pooja Prabhakar, 17 Kingston Apartments, M G Ramachandran Road Kalakshetra Colony, Chennai - 600 090. [Pan: Bcgpp-8061-H] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By Ito, Vs. Non-Corp Ward -15(1), Chennai. (प्रत्यर्थी/Respondent) : Mr. R. Venkataraman, Fca & Mr. K. Vishwa Padmanabhan, Fca. : Shri. Arv Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /Order Per S. R. Raghunatha, Am : : 16.12.2025 : 01.01.2026 These Three Appeals Preferred By The Assessee Are Directed Against The Separate Orders, Each Dated 25.08.2025, Passed By The Learned Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As “Ld. Cit(A)”). The Impugned Orders Arise Out Of The Assessments Framed By The National Faceless Assessment Centre (Hereinafter Referred To As The "Ao”) U/S.147 R.W.S 144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As "The Act"), Pertaining To Assessment Years 2015-16, 2016-17 & 2017-18 :-2-:

Section 144Section 147Section 148Section 148ASection 201Section 69A

National Faceless Appeal Centre, Delhi (hereinafter referred to as “Ld. CIT(A)”). The impugned orders arise out of the assessments framed by the National Faceless Assessment Centre (hereinafter referred to as the "AO”) u/s.147 r.w.s 144 of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), pertaining ... Without prejudice to the above, that the Ld.CIT(A) erred in not appreciating that the assessment order dated 23.03.2022 passed by the National Faceless Assessment Centre [“Assessing Officer”] u/s.147 r.w.s 144 of the Act for the Assessment Year 2015-16 is invalid, void ab initio, and liable to be quashed

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

In the result, all the three appeals of the assessee for the A

ITA 3047/CHNY/2025[2016-17]Status: DisposedITAT Chennai01 Jan 2026AY 2016-17

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Mr. R. Venkataraman, FCA &For Respondent: Shri. ARV Sreenivasan, CIT

Section 144Section 147Section 148Section 148ASection 201Section 69A

National Faceless Appeal Centre, Delhi (hereinafter referred to as “Ld. CIT(A)”). The impugned orders arise out of the assessments framed by the National Faceless Assessment Centre (hereinafter referred to as the “AO”) u/s.147 r.w.s 144 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”), pertaining ... Without prejudice to the above, that the Ld.CIT(A) erred in not appreciating that the assessment order dated 23.03.2022 passed by the National Faceless Assessment Centre [“Assessing Officer”] u/s.147 r.w.s 144 of the Act for the Assessment Year 2015-16 is invalid, void ab initio, and liable to be quashed

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

ITA 3046/CHNY/2025[2015-16]Status: DisposedITAT Chennai01 Jan 2026AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:3046, 3047 & 3048/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16, 2016-17 & 2017-18 Pooja Prabhakar, 17 Kingston Apartments, M G Ramachandran Road Kalakshetra Colony, Chennai - 600 090. [Pan: Bcgpp-8061-H] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By Ito, Vs. Non-Corp Ward -15(1), Chennai. (प्रत्यर्थी/Respondent) : Mr. R. Venkataraman, Fca & Mr. K. Vishwa Padmanabhan, Fca. प्रत्यर्थी की ओर से/Respondent By : Shri. Arv Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing : 16.12.2025 घोषणा की तारीख/Date Of Pronouncement : 01.01.2026 आदेश /Order Per S. R. Raghunatha, Am : These Three Appeals Preferred By The Assessee Are Directed Against The Separate Orders, Each Dated 25.08.2025, Passed By The Learned Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As “Ld. Cit(A)”). The Impugned Orders Arise Out Of The Assessments Framed By The National Faceless Assessment Centre (Hereinafter Referred To As The "Ao”) U/S.147 R.W.S 144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As "The Act"), Pertaining To Assessment Years 2015-16, 2016-17 & 2017-18 :-2-:

For Respondent: Shri. ARV Sreenivasan, CIT

Section 144Section 147Section 148Section 148ASection 69A

Esi Hospital Employees Co-Op Thrift & Credit Society Ltd., Chennai vs. ITO, Ncw-10(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 3030/CHNY/2025[2016-17]Status: DisposedITAT Chennai01 Jan 2026AY 2016-17

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. G Reddi Prakash, F.C.AFor Respondent: Shri. ARV Sreenivasan, CIT

Section 147Section 148Section 148ASection 151ASection 80P

does not matter if the Jurisdictional Assessing Officer (JAO) issues the notice and it is not mandatory that it should be issued by the Faceless Assessment Officer (FAO). Another learned Single Judge in order dated 21.04.2025 in WP No.22402 of 2024 and batch cases, followed what was held ... Judge was pleased to dismiss the petition on the ground that even if the notice has been issued by Jurisdictional Assessment Officer and not Faceless Assessment Officer, the notice issued under Section 148A/148 of the Income Tax Act will be valid. 3. Ms.Vardhini Karthik submitted that this Court

Syntel Private Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 11(2)(2), Mumbai

Accordingly, Ground No. 3 & 4 raised by the Assessee is allowed for statistical purposes

ITA 6863/MUM/2025[2018-19]Status: DisposedITAT Mumbai01 Jan 2026AY 2018-19

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

For Appellant: Shri Ketan Ved &For Respondent: Shri Arun Kanti Datta

Section 115JSection 143(3)Section 144BSection 234CSection 37

assessment order to be invalid and void ab initio, having been passed by the Additional/Joint/Deputy/Assistant Commissioner of Income Tax/ Income-tax Officer, National Faceless Assessment Centre, Delhi without issuing a mandatory show cause notice as required under the National Faceless Assessment Scheme, 2019. Addition of Rs.33,83,80,861 under