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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

Pooja Aggarwal, Panchkula vs. ACIT(Central) Shimla, Shimla

Appeal stand allowed in terms of our above order

ITA 1026/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh24 Nov 2025AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1026/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Ms. Pooja Aggarwal Acit Central बनाम/ Vs. House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abnpa-6660-N (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca)A/W Shri Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 15-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-07-2025 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 Of The Act On 12-03-2025. The Assessee Is Aggrieved By Confirmation Of Substantive Addition Of Rs.16.21 Lacs & Protective Addition Of Rs.10.95 Lacs. The Additions Stem From Search Action By The Department On Assessee-Group On 04-

For Appellant: Sh. Ajay Jain (CA)a/w Shri Lovesh BansalFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR
Section 127Section 144BSection 147Section 148Section 151A

derogation of the provisions of Sec.151A read with CBDT Notification No.18/2022 dated 29-03-2022 which mandate issuance of such notice by Faceless Assessing Officer (FAO) only. The Ld. AR further contended that in terms of ratio of various decisions of jurisdictional High Court, issuance of notice ... Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO) would vitiate the entire assessment proceedings. The Ld. AR referred to notice issued by Ld. AO u/s 148 on 29-12-2023 which is kept on Page No.7 of the paper-book. This notice has been issued by G Poojitha

Anup Kumar Aggarwal, Panchkula vs. ACIT(Central) Shimla, Shimla

Appeal stand allowed in terms of our above order

ITA 1019/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh24 Nov 2025AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1019/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Sh. Anup Kumar Aggarwal Acit (Central) बनाम/ Vs. House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Adjpk-5842-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Shri Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 15-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-07-2025 In The Matter Of An Assessment Framed By Ld. Ao U/S 147 Of The Act On 12-03-2025. The Assessee Is Aggrieved By Confirmation Of Additions Of Rs.10.95 Lacs U/S 69 & Another Addition Of Rs.16.21 Lacs U/S 69A. The Additions Stem From Search Action By The Department On Assessee-Group On 04-

For Appellant: Sh. Ajay Jain (CA) a/w Shri Lovesh BansalFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR
Section 127Section 144BSection 147Section 148Section 151ASection 69Section 69A

derogation of the provisions of Sec.151A read with CBDT Notification No.18/2022 dated 29-03-2022 which mandate issuance of such notice by Faceless Assessing Officer (FAO) only. The Ld. AR further contended that in terms of ratio of various decisions of jurisdictional High Court, issuance of notice ... Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO) would vitiate the entire assessment proceedings. The Ld. AR referred to notice issued by Ld. AO u/s 148 on 29-12-2023 as placed on record. This notice has been issued by G Poojitha DCIT / ACIT (Central) Shimla who happens

M. Agathiyan, Thiruvarur vs. ITO, Ward-1, Tiruvarur

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

ITA 2521/CHNY/2025[2020-21]Status: DisposedITAT Chennai24 Nov 2025AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.2521/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Muthuvel Agathiyan, Vs. The Income Tax Officer, 18, Keela Fourth Street, Mannargudi Ward 1, Post, Mannargudi, Thiruvarur 614 001. Thiruvarur. [Pan:Aihpa1940J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Kaarthick, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.10.2025 घोषणा की तारीख /Date Of Pronouncement : 24.11.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.07.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21. 2. When The Appeal Was Taken Up For Hearing, The Ld. Ar Shri S. Kaarthick, Advocate Drew Our Attention To Ground No. K Raised In The Grounds Of Appeal & Submits That The Assessee Challenged

For Appellant: Shri S. Kaarthick, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 133(6)Section 135ASection 139(1)Section 147Section 148Section 148A

submits that no updated ITR under section 139(8A) of the Act has been filled by the assessee. She further submits that if a Faceless Assessment Unit (FAU) has a FVR with remarks suggesting a return under section 139(8A) of the Act should have been updated ... under section 139(8A) of the Act. Upon perusal of the e-Verification Instruction No. 2(i) of 2024, we note that if a Faceless Assessment Unit (FAU) has a FVR with remarks suggesting a return under section 139(8A) of the Act should have been updated

Shamsudeen Abdul Khadar, Kollam vs. ITO, Ward-2, Kollam

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

ITA 768/COCH/2025[2017-18]Status: DisposedITAT Cochin21 Nov 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Shamsudeen Abdul Khadar .......... Appellant Nusaifa Manzil, Chithara, Madathara Kottarakkara, Kollam 691541 [Pan: Arjpa0218Q] Vs. The Income Tax Officer, Ward-2, Kollam .......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 15.07.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. The Appellant Had Not Filed The Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) For Ay 2017-18. Based On The Information That The Appellant Had Deposited Cash Amounting To Rs. 12,07,500/- During Ay 2017-18 In Bank Account Maintained With Kerala Grameen Bank, The Ao Formed An Opinion That Income Escaped Assessment To Tax. Therefore, The Ao

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 68

income on 29.05.2020 declaring total income of Rs. 3,69,350/-. Against the said return of income, the assessment was completed by the National Faceless Assessment Centre, Delhi (hereinafter called "the AO") vide order dated 20.09.2021 passed u/s. 147 r.w.s. 144B of the Act at total income

Kadukutty Service Co-Operative Bank Ltd - No: 628, Thrissur vs. Ward 1, (1), Thrissur

In the result, the appeal filed by the assessee stands dismissed

ITA 636/COCH/2025[2013-14]Status: DisposedITAT Cochin21 Nov 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2013-14 Kadukutty Service Co-Op. Bank Ltd. .......... Appellant Kadukutty P.O., (Via) Chalakkudy, Thrissur [Pan: Aabak0755A] Vs. The Income Tax Officer, Ward-1(1), Thrissur .......... Respondent Assessee By: Shri Yash, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.10.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 18.07.2025 For Assessment Year (Ay) 2013-14. 2. Brief Facts Of The Case Are That The Assessee Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Appellant Had Not Filed Return Of Income For Ay 2013-14 Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act). Based On The Information That The Appellant Had Deposited Cash In The Bank

For Appellant: Shri Yash, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139Section 139(1)Section 142(1)Section 147Section 148Section 80ASection 80A(5)Section 80P

that the appellant had deposited cash in the bank 2 Kadukutty Service Co-op. Bank Ltd. account of Rs. 12,03,000/-, the National Faceless Assessment Centre, Delhi (hereinafter called "the AO") issued a notice u/s. 148 of the Act on 08.05.2020 after taking prior approval

Assistant Commissioner of Income Tax, Corporate Circle 1(1), Chennai vs. Bahwan Cybertek Pvt Ltd, Chennai

ITA 1836/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Nov 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1836/Chny/2024 & C.O.No.62/Chny/2024 (In Ita No.: 1836/Chny/2024) निर्धारण वर्ष / Assessment Year: 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. (अपीलार्थी/Appellant) Bahwan Cybertek Private Limited, Vs. No.148, Bahwan Cybertek It Park, Rajiv Gandhi Salai (Omr), Okkiyam, Thoraipakkam, Chennai - 600 097. [Pan: Aabcb- 2020-P] (प्रत्यर्थी/Respondent/ Cross Objector) It(Tp) A No.: 22/Chny/2024 निर्धारण वर्ष / Assessment Year: 2017-18 Bahwan Cybertek Private Limited, No.148, Bahwan Cybertek It Park, Rajiv Gandhi Salai (Omr), Okkiyam, Thoraipakkam, Chennai - 600 097. [Pan: Aabcb- 2020-P] (अपीलार्थी/Appellant) Vs. Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. (प्रत्यर्थी/Respondent) Assessee By Department By : Shri. N. V. Balaji, Advocate : Shri. Ar. V. Sreenivasan, C.I.T. सुनवाई की तारीख /Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 29.10.2025 : 21.11.2025 आदेश /O R Der Per S. R. Raghunatha, Am : These Appeals Are Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeals) -16, Chennai [Hereinafter Referred To As The “Ld.Cit(A)”] For The

For Respondent: Shri. N. V. Balaji, Advocate
Section 143(3)Section 250Section 92C

Ld.CIT(A)”] for the assessment year (A.Y.) 2017-18 arising out the final assessment order dated 26.11.2021 passed by the Assessing Officer, National Faceless Assessment Centre – Delhi, (AO) u/s.143(3) r.w.s.144C of the Income Tax Act, 1961 (hereinafter “the Act”). 1.1 At the outset, we find that there