“faceless assessment”

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

follows: 1On facts and circumstances of the case and in law, the re-assessment order passed u/s 147 dated 29/03/2022 by the National Faceless Assessment Centre (NFAC) is grossly bad in law, since the jurisdiction of the NFAC prescribed u/s.151A had been notified w.e.f. 29/03/2022 and accordingly, the assumption ... legal issue raised by the assessee, first time stating that the re-assessment order passed u/s 147 dated 29/03/2022 by the National Faceless Assessment Centre (NFAC) is grossly bad in law, since the jurisdiction of the NFAC prescribed u/s.151A had been notified with effect from (w.e.f.) 29/03/2022 and accordingly

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita Nos. 498 & 499/Rjt/2025 निर्धारणवर्ष /Assessment Years: 2015-16 & 2020-21 Gopal Snacks Pvt. Ltd. बनाम Asst. Commissioner Of Income Tax Circle-1(1), Rajkot Plot No.2322-2324, Gidc Metoda, Lodhika, Rajkot, Gujarat-360021 (अपीलार्थी/Appellant) Pan : Aadcg6113A (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राजस्व की ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 19/11/2025 घोषणा की तारीख/Date Of Pronouncement : 08/12/2025 Order Per, Dr. Arjun Lal Saini: Captioned Two Appeals Filed By The Same Assessee, Pertaining To

follows: 1On facts and circumstances of the case and in law, the re-assessment order passed u/s 147 dated 29/03/2022 by the National Faceless Assessment Centre (NFAC) is grossly bad in law, since the jurisdiction of the NFAC prescribedu/s.151A had been notified w.e.f. 29/03/2022 and accordingly, the assumption of jurisdiction ... legal issue raised by the assessee, first time stating that the re-assessment order passed u/s 147 dated 29/03/2022 by the National Faceless Assessment Centre (NFAC) is grossly bad in law, since the jurisdiction of the NFAC prescribed u/s.151A had been notified with effect from (w.e.f.) 29/03/2022 and accordingly

Boddu Sai Baba, Tadepalligudem vs. Income Tax Officer, Ward-1, Tadepalligudem

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.571/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Boddu Sai Baba, Vs. Income Tax Officer, Tadepalligudem. Ward-1, Pan: Ahspb0015F Tadepalligudem. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 26/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 08/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 27/12/2023, For The Assessment Year 2018-19. The Assessee Has 2 Boddu Sai Baba Vs. Ito

notice u/s 148 is invalid in as much as: i) The said notice was issued by the Jurisdictional Assessing Officer (JAO) as against the Faceless Assessing officer (FAO) contrary to the mandate of S. 151A of the Act. ii) ii) the said notice was issued with the approval of PCIT ... that notice under section 148 of the Act, dated 01/04/2022 had been issued by the Jurisdictional Assessing Officer (JAO) as against the Faceless Assessing Officer (FAO), which was contrary to the mandate of section 151A of the Act. Apropos the contention that the AO had erred in not granting

Seelamsetty Balaji, Vijayawada vs. Income Tax Officer, Ward-2(1), Vijayawada

In the result, appeal of the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble

challenging the validity of the issue of notice under section 148 of the Act by the Jurisdictional Assessing Officer (JAO) and not by a Faceless Assessing Officer (FAO). 8. On this issue, the Ld. Authorised Representative [hereinafter “Ld.AR”] submitted that the Jurisdictional Assessing Officer has issued notice under section ... Ld.AR further submitted that consequent to notification regarding the e-assessment proceedings dated 29.03.2022 notice under section 148 shall be issued by the Faceless Assessing Officer and not by the Jurisdictional Assessing Officer. He therefore pleaded that since the notice is invalid the consequent assessment proceedings is not valid

Venkata Ramana Goda, Visakhapatnam vs. Assisstant Commissioner of Income Tax, Circle-3(1), Visakhapatnam

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.489/Viz/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Venkata Ramana Goda, Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Circle-3(1), Pan: Abzpg3216A Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Mrs. K. Hemalatha, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 17/11/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/08/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 08/03/2025. The 2 Venkata Ramana Goda Vs. Acit

invalid in terms of section 151A as per which notice u/s 148 shall be issued through automated allocation by National Faceless Assessing Officer ('NFAC') and this action of JAO rendered the entire re- assessment proceedings void-ab-initio. Ground challenging the addition made by Ld. AD regarding the alleged receipts ... assessee had before the CIT(A) assailed the validity of the jurisdiction that was assumed by the Assessment Unit, Income-tax Department, i.e., the Faceless Assessing Officer (FAO) for framing the assessment, for the reason that as per the “e-Assessment of Income Escaping Assessment Scheme, 2022” which was effective

Shakir Mohmmad, Visakhapatnam vs. The Income Tax Officer, Ward-2(5), Visakhapatnam

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.280/Viz/2025 (िनधा"रण वष"/Assessment Year:2018-19) Shakir Mohmmad, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Pan: Cffpm2965E Visakhapatnam. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 02/12/2025 Hearing: घोषणा की तारीख/Date Of 05/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm :

Faceless Scheme of Assessment had come into force w.e.f 29/03/2022 and all the notices thereafter were required to be issued by the Faceless Assessment Unit, but the CIT(A) despite the fact that the assessee in support of his contention had relied upon the judgment of the Hon’ble Jurisdictional ... notice issued under section 148 of the Act, dated 31/03/2022, inter alia, for the reason that the same was not issued by the Faceless Assessing Officer (FAO) as was mandatorily required pursuant to the Faceless re- assessment scheme as was made available on the statute w.e.f 29/03/2022

Income Tax Officer, Ashoknagar vs. Ajit Singh, Shivpuri

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

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh (Through Virtual Hearing) Income Tax Officer, Vs. Ajit Singh, Ashoknagar, Village-Haatodh, Madhya Pradesh Post-Kota, Shivpuri (Appellant) (Respondent) Pan: Ccnps7470K Assessee By : Shri Vipin Upadhyay, Adv Revenue By: Shri Sukesh Kumar Jain, Cit(Dr) Date Of Hearing 17/11/2025 Date Of Pronouncement 04/11/2025

opening, assessment stands pending as on 01.04.2021. Under these circumstances, the re-opened assessment has to be completed u/s 144B (i.e. Faceless assessment system) as per Boards instruction F. No. 187/3/2020-ITA-I, dated 31.03.2021. 4.4. The relevant instruction is as follows. ― In pursuance of sub-section (2) of Section 144B ... once again reiterated that in the instant case, the assessment is pending as on 01.04.2021 and the case is not shifted to faceless assessment unit. Instead it is completed by the jurisdictional assessing officer [ITO-Ashok Nagar]. There is nothing on record that the Principal Chief Commissioner or the Principal

Brahmani Developers Pvt Ltd, Rourkela vs. ACIT, Circle Rourkela, Rourkela

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

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.330/Ctk/2024 ("नधा"रण वष" / Assessment Year : 2018-19) Brahmani Developers Pvt Ltd., K4- Vs Acit, Rourkela Circle, Rourkela 9, Civil Township, Rourkela769004 Pan No. : Aadcb 2197 H (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri P.R.Mohanty, Adv राज"व क" ओर से /Revenue By : Shri Vijaya Singh, Ld Sr Dr सुनवाई क" तार"ख / Date Of Hearing : 4 /12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 4 /12/2025 आदेश / O R D E R Per Bench :

सं/ITA No.330/CTK/2024 ("नधा"रण वष" / Assessment Year : 2018-19) physical form before the Jurisdictional Assessing Officer for verification as per the SOP of faceless assessment scheme, the same had also been rejected by the Faceless Assessing Officer and addition had been made. It was the submission that the assessee

Shri Ikbalbhai Jumabhai Khirani, Rajkot vs. The ITO Ward-1 (2) (1), Rajkot

Bench: Dr. Arjun Lal Saini

proceedings u/s 144B of the Act by the NFAC. Subsequent to the notice u/s.148 of the Act, assessee’s case was assigned to the Faceless assessment proceedings u/s 147 r.ws 144B of the Act. Accordingly, assessee has been issued notice u/s. 142(1) of the Act dated