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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

Somineni Vijayalakshmi, Secunderabad vs. ITO, Ward-11(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1697/HYD/2025[2016-17]Status: DisposedITAT Hyderabad19 Dec 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1697/Hyd/2025 Assessment Year 2016-2017 Somineni The Income Tax Officer, Vijayalakshmi, Vs. Ward-11(1), Hyderabad – 500 055. Hyderabad. Pan Ahtpv9907H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Cs Subrahmanyam & Sri V Siva Kumar, Advocate राज" व "ारा /Revenue By: Sri Ashutosh Pradhan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 10.12.2025 घोषणा की तारीख/Pronouncement: 19.12.2025 आदेश/Order

For Appellant: CA CS Subrahmanyam and Sri V Siva Kumar, AdvocateFor Respondent: Sri Ashutosh Pradhan, Sr. AR
Section 147Section 148Section 148ASection 271DSection 69A

Officer [in short “JAO”] and 4 ITA.No.1697/Hyd./2025 consequently, the re-assessment order on the ground that the procedure as per the National Faceless Assessment Scheme has not been followed. 4. We have heard the learned Authorised Representative of the Assessee as well as the learned DR and considered ... notice u/sec.148 for reopening of the assessment were issued by the Jurisdictional Assessing Officer, without following the procedure as per the National Faceless Assessment Scheme. An identical issue has been considered by this Bench of Hyderabad Tribunal in the case of Vijay Kumar Kamdar, Adilabad vs., ITO, Ward-1, Adilabad

Sidhampoondi Pa Cultural Coop Bank Ltd. S 1392, Namakkal vs. ITO, Ward-2, Namakkal

ITA 3070/CHNY/2025[2019-20]Status: DisposedITAT Chennai19 Dec 2025AY 2019-20

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.3070/Chny/2025 निर्धारण वर्ष/Assessment Year: 2019-20 Sidhampoondi Pa Cultural Co-Op Bank Ltd S 1392, 2/173, Main Road, Kondarasampalayam Post P. Velur Tk, Namakkal-637203 Tamil Nadu [Pan: Aabas 0168 F] (अपीलार्थी/Appellant) V. Ito, Ward-02, Namakkal, Tamil Nadu-6370001 (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : None प्रत्यर्थी की ओर से / Respondent By : Mr. Arv Srinivasan, Cit सुनवाईकीतारीख/Date Of Hearing : 18.12.2025 घोषणाकीतारीख /Date Of Pronouncement : 19.12.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeal By The Assessee Is Arising Out Of The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi Dated 12.08.2025 For Ay 2019-20. 2. At The Outset, We Notice That The Assessee By The Ground No.2 Challenges The Jao Jurisdiction To Issue Notice U/S148 Dated 30.03.2023 Of The Act.

For Appellant: NoneFor Respondent: Mr. ARV Srinivasan, CIT
Section 144BSection 147Section 148

issue has held as under: 1. A common issue has arisen in the captioned petitions, i.e., whether the Jurisdictional Assessing Officer (‘JAO') or the Faceless Assessing Officer (‘FAO') would have the jurisdiction to initiate re-assessment proceedings under Section 148 of the Income-Tax Act, 1961 (‘the Act, hereinafter