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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

Mr. Jitendra Walia, Hardwar vs. ITO, W-1(3)(1) 44(2), Haridwar

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

ITA 115/DDN/2025[2015-16]Status: DisposedITAT Dehradun27 Nov 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalmr. Jitendra Walia, Income Tax Officer, 653, Sarai Road, Ward-1(3)(1), 44(2), Jwalapur, Haridwar-249407. Vs. Haridwar. Pan:Abvpw9014C (Appellant) (Respondent) Assessee By Shri Tarandeep Singh, Adv. & Shri Sandeep Yadav, Adv. Department By Shri A.S. Rana, Sr. Dr Date Of Hearing 11.09.2025 Date Of Pronouncement 27.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Cit(A) In Short) Passed U/S 250 Of The Income Tax Act, 1961, Dated 22.04.2025 For Assessment Year 2015-16. 2. At The Outset, It Is Seen That The Appeal Of The Assessee Is Dismissed By The Ld. Cit(A) For Non-Prosecution. Before Us, The Ld. Ar Submitted That The Ld. Cit(A) Has Issued Notices Which Were Delivered To The Registered Email Address Of The Appellant & Were Also Uploaded In The Portal Of The Department, However, The Assessee Was Not Aware Of The Proceedings Nor Such Notices Were Brought To His Knowledge By The Accountant Of The Assessee, Therefore, The Necessary Compliance Could Not Be Made Either Before The Ao Or Before The Cit(A). He Thus

Section 250

assessee. 4. After considering the arguments, we find that in the instant case, the assessee was not aware of such drastic changes in faceless assessment schemes and was unware of all the activities like issue of notices through email and to respond such notices online, therefore, due compliance could

Arkay Energy (Rameswarm) Private Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

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

ITA 1562/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.1562/Hyd/2025 (निर्धारण वर्ष/Assessment Year:2017-18) M/S. Arkay Energy (Rameswarm) Pvt. Ltd., Hyderabad. Vs. Dy. Commissioner Of Income Tax, Circle 1(1), Hyderabad. Pan: Aafca0044C (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao, C.A. राजस्व द्वारा / Revenue By: Shri Ranjan Agrawala, Sr-Dr सुनवाई की तारीख /Date Of Hearing: 20/11/2025 घोषणा की तारीख / Pronouncement: 26/11/2025 आदेश/Order Per Vijay Pal Rao: This Appeal By The Assessee Is Directed Against The Order Dated 23.07.2025 Of National Faceless Appeal Centre (Nfac), Delhi For The

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Shri Ranjan Agrawala, SR-DR
Section 143(3)Section 147Section 148Section 148ASection 151ASection 250

failed to appreciate the fact that the notice u/s 148 dated 31/03/2024 was issued by the DCIT, Circle-1(1), Hyderabad instead of National Faceless Assessment Centre (NFAC), Delhi, as mandated u/s 151A r.w.s 144B of the Act, which is invalid & without jurisdiction. 4. The Ld. CIT(A) failed ... SRINIVASA RAO CIRCLE 1(1), HYDERABAD 6. Thus the notice was issued by Jurisdictional Assessing Officer without following the procedure as per the National Faceless Assessment Scheme notified by the Government. An identical issue has been considered by this Tribunal in the case of ITO Vs. Meghana Enterprises (supra