“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

Jayshree Chandrasingh Kabali, Mumbai vs. DCIT Circle 27 (1), Mumbai

In the result, both the stay petitions of the assessee are dismissed and both the appeals are allowed for statistical purposes

ITA 7225/MUM/2025[2017-18]Status: DisposedITAT Mumbai21 Nov 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

For Appellant: Shri Mehul Shah, CAFor Respondent: Shri Annavaram K., Sr. DR

Section 142(1)Section 143(3)Section 144Section 147Section 148Section 271ASection 69

Faceless Appeal Centre (NFAC), Delhi vide order nos. ITBA/NFCA/S/250/2025-26/1080151012(1) and ITBA/NFCA/S/250/2025-26/1080177826(1) dated 29.08.2025 passed against the assessment and penalty orders by National Faceless Assessment Centre, Delhi, u/s. 147 r.w.s. 144 r.w.s. 144B and 271AAC(1) of the Income-tax Act, 1961 (hereinafter referred

Mukeshkumar Bhawarlal Jain, Mumbai vs. ITO 23(2)(6), Mumbai

In the result, assessee’s appeal is allowed for statistical purposes

ITA 6694/MUM/2024[2014-15]Status: DisposedITAT Mumbai21 Nov 2025AY 2014-15

Bench: Smt Beena Pillai & Smt.Renu Jauhri7 (A.Y.2014-15)

For Appellant: Mr. Suchek AnchaliyaFor Respondent: Shri Annavaran Kosuri- Sr. DR

Section 144BSection 147Section 148Section 148ASection 151Section 250Section 69A

valid without appreciating the fact that the said notice was issued by the Ld. Jurisdictional Assessing Officer and not by the National Faceless Assessment Centre in contravention of the faceless scheme and notification issued by the Central Board of Direct Taxes in Notification no. 18 of 2022. Additional Ground

Dsv Air & Sea Private Limited, Mumbai vs. ACIT, Cirle-3(1)(1), Mumbai

In the result, this ground of appeal is allowed for statistical purpose

ITA 3653/MUM/2024[2020-21]Status: DisposedITAT Mumbai21 Nov 2025AY 2020-21

Bench: Shri Pawan Singh& Smt.Renu Jauhri(Physical Hearing)

Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 253Section 254(1)Section 92CSection 92C(3)

against the order dated on 30 May 2024 passed by the Additional Joint/Deputy/Assistant Commissioner of Income-tax/Income-tax officer, National Faceless Assessment Centre, New Delhi, Assessment Unit, Income-Tax Department (learned AO") issued under Section 143(3) read with Section 144C(13) read with Sections 144(B), ('final assessment

Kusum Sahgal, Gurugram vs. ACIT, Circle-19(2), Delhi

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

ITA 341/DEL/2025[2016-17]Status: DisposedITAT Delhi21 Nov 2025AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2016-17 Kusum Sahgal, Through Lr Shri Vs. Acit, Circle-19(2), Viney Sagar Sahgal, New Delhi Mg-2002, The Magnolias, Golf Course Road Dlf Phase-V, Gurugram, 122 002 Haryana Pan :Aatps3766J (Appellant) (Respondent)

Section 133(6)Section 142(1)Section 143(2)Section 250Section 54BSection 54ESection 54F

VIMAL KUMAR, JUDICIAL MEMBER: The appeal filed by the assessee is against order dated 12.12.2024 of Learned Commissioner of Income Tax (Appeals)/National Faceless Assessment Centre (NFAC), Delhi (hereinafter referred as “the Ld. CIT(A)”) under Section 250 of the Income Tax Act, 1961 (hereinafter referred as “the Act”) arising

Muraleedharan Pillai Arunkumar, Kollam vs. ITO Ward 1 & Tps, Alappuzha

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

ITA 690/COCH/2025[2017-18]Status: DisposedITAT Cochin20 Nov 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Muraleedharan Pillai Arunkumar .......... Appellant Karuvazhathu House, Thevalakara P.O. Palickal, Karunagappally 690524 [Pan: Avjpa3922F] Vs. The Income Tax Officer, Wd-1&Tps, Alappuzha.......... Respondent Assessee By: Shri R. Krishnan, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 29.10.2025 Date Of Pronouncement: 20.11.2025 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 30.07.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. No Regular Return Of Income For Ay 2017-18 Was Filed By The Appellant. Based On The Information That The Appellant Made Cash Deposits Of Rs. 1,65,98,650/- National Faceless Assessment Centre, Delhi (Hereinafter Called "The Ao") Formed An Opinion That Income Escaped Assessment To Tax. Accordingly, A Notice U/S. 148 Of The Income Tax Act, 1961 (The Act) Was Issued On 30.03.2021. In 2 Muraleedharan Pillai Arunkumar Response To The Notice U/S. 148, The Appellant Filed Return Of Income On 29.11.2021 Disclosing Income Of Rs. 3,00,990/-. Against The Said Return Of Income, The Assessment Was Completed By The Ao Vide Order Dated 29.03.2022 Passes U/S. 147 R.W.S. 144B Of The Act At Total Income Of Rs. 30,70,746/-. While Doing So, The Ao Made Addition Of Cash Deposits Of Rs. 20,11,631/- S Unexplained Money Of The Appellant. The Ao Also Made Addition On Account Of Vendor Commission Of Rs. 7,58,125/-.

For Appellant: Shri R. Krishnan, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 142(1)Section 147Section 148

filed by the appellant. Based on the information that the appellant made cash deposits of Rs. 1,65,98,650/- National Faceless Assessment Centre, Delhi (hereinafter called "the AO") formed an opinion that income escaped assessment to tax. Accordingly, a notice u/s. 148 of the Income

Sowmya Kannan, Chennai vs. ITO, Ward-19(4), Chennai

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

ITA 2524/CHNY/2025[2015-16]Status: DisposedITAT Chennai20 Nov 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2524/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 Ms. Sowmya Kannan, The Income Tax Officer, No.634-A, Ramasamy Salai, Vs. Non-Corporate Ward 19(4), K K Nagar, Chennai. Chennai – 600 078. Pan: Aaopk 5170F (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Abhishek Murali, Ca ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 20.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 20.11.2025

For Appellant: Shri Abhishek Murali, CAFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 144BSection 147Section 148Section 148ASection 250

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

Swiss Re Asia Pte Ltd, Singapore vs. Deputy Commissioner of Income Tax, (International Taxation) Circle - 4(2)(2), Mumbai

In the result, we hold that the assessee does not have any permanent establishment in India, whether as fixed place

ITA 4092/MUM/2023[2021-22]Status: DisposedITAT Mumbai20 Nov 2025AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 144CSection 9(1)(i)

year 2020-21, Ground 1 challenges the validity of assessment on the footing that notice under section 143(2) was issued by the National Faceless Assessment Centre instead of the jurisdictional Assessing Officer. During the course of hearing, this ground was not pressed and we therefore dismiss

Swiss Re Asia Pte Ltd, Singapore vs. Deputy Commissioner of Income Tax, (International Taxation) Circle - 4(2)(2), Mumbai

In the result, we hold that the assessee does not have

ITA 3178/MUM/2023[2020-21]Status: DisposedITAT Mumbai20 Nov 2025AY 2020-21

Section 144CSection 9(1)(i)

Aroma Chemicals, Moradabad vs. ACIT, Circle-1, Moradabad

In the result, appeal filed by the assessee is allowed

ITA 2465/DEL/2025[2015-16]Status: DisposedITAT Delhi20 Nov 2025AY 2015-16

Bench: Yogesh Kumar U.S. & Shri Brajesh Kumar Singh

Section 144Section 147Section 148Section 68

r.w.s. 144 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred ITA No.- 2465/Del/2025 Aroma Chemicals to as ‘the Act’) by the National Faceless Assessment Centre, Delhi, (hereinafter referred to as the ‘Ld. AO’) pertaining to A.Y. 2015-16. 2. In this case, the assessment was reopened vide notice

Anjaneyulu Reddy Ammireddy, Vinukonda vs. Income Tax Officer, Ward-1, Narasaraopet

ITA 542/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.542/Viz/2025 (निर्धारण वर्ा/Assessment Year:2018-19) Vs. Anjaneyulu Reddy Ammireddy, Income Tax Officer, Vinukonda. Ward-1, Pan: Aelpa3332C Narasaraopet. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri Gvn Hari, Advocate रधजस्‍व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of Hearing: 06/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 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 25/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 29/02/2024. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal:

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 151Section 151ASection 69

appellant u/s 250 of the Income Tax Act, 1961 have been issued online through the ITBA software, as is required under the Faceless Assessment & Appeals. 6.3 The decision of the Hon'ble High Court of Mumbai in the case of Mis. Chemipol vis. Union of India [Central Excise Appeal No.62

Ashok Rudraraju, Visakhapatnam vs. Income-Tax Officer, Ward-2(5), Visakhapatnam

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

ITA 439/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 439/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2016-17) Ashok Rudraraju, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Visakhapatnam. Pan: Aqvpr4058L

For Appellant: Shri I. Kama Sastry, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 147Section 148Section 148ASection 149(1)(b)Section 151Section 151(1)Section 151ASection 251(1)(a)Section 69A

CCIT; CCIT; Pr. CIT or CIT as mandated by the provisions of section 151(1) as applicable upto 31.03.2021. 5. The Assessment Unit, National Faceless Assessment Centre is not justified in making the addition of Rs. 30,12,755 /- as unexplained money under section 69A of the Income ... Ostensibly, the assessee had, inter alia, assailed the validity of the jurisdiction that was assumed by the Jurisdictional Assessing Officer (JAO) as against the Faceless Assessing Officer (FAO) as per the scheme framed under section 151A of the Act and notified on 29/03/2022 for issuing notices under section

Sree Pazhanchira Devi Temple, Trivandrum vs. Assessing Officer, Exemption Ward, Tvm

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

ITA 826/COCH/2025[2013-2014]Status: DisposedITAT Cochin19 Nov 2025AY 2013-2014

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2013-14 Sree Pazhanchira Devi Temple Trust .......... Appellant Poonthura P.O., Ambalathara Thiruvananthapuram 695026 [Pan: Aamts1272L] Vs. Ito (Exemption), Thiruvananthapuram ......... Respondent Assessee By: Shri R. Krishnan, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 07.11.2025 Date Of Pronouncement: 19.11.2025

For Appellant: Shri R. Krishnan, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 138Section 142(1)Section 148

appellant neither complied with the notice u/s. 148 nor the notices issued u/s. 142(1) of the Act. In the circumstance, the National Faceless Assessment Centre, Delhi (hereinafter called "the AO") was constrained to pass best judgement assessment treating the cash deposits as unexplained money of the trust. Accordingly made

Naippalli Chirayil Chandy Joseph, Alappuzha vs. ITO Ward 2, Alappuzha

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

ITA 748/COCH/2025[2015-16]Status: DisposedITAT Cochin19 Nov 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2015-16 Naippalli Chirayil Chandy Joseph .......... Appellant Naippallichirayil House, Edathua, Alappuzha [Pan: Anspj6746P] Vs. The Income Tax Officer, Ward-2, Alappuzha .......... Respondent Assessee By: Shri K. Balaji, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 04.11.2025 Date Of Pronouncement: 19.11.2025 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 18.08.2025 For Assessment Year (Ay) 2015-16. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. No Regular Income For Ay 2015-16 Was Filed By The Appellant. Based On The Information That The Appellant Made Cash Deposits In Bank Account During The Previous Year Relevant To Ay 2015-16, Ao Formed An Opinion That Income Escaped Assessment To Tax. Accordingly, A Notice U/S. 148 Of The Income Tax Act, 1961 (The Act) Was Issued On 07.04.2022 After Complying With The Procedures

For Appellant: Shri K. Balaji, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 147Section 148Section 148A

148A of the Act. In response to the notice u/s. 148, the appellant had not filed return of income. In the circumstances the National Faceless Assessment Centre, Delhi [CIT(A)] (hereinafter called "the AO") completed the assessment vide order dated 15.01.2024 passed u/s. 147 r.w.s. 144B

Waterworld Tourism Company Private Limited, Alappuzha vs. ITO Ward 1 & Tps, Alappuzha

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

ITA 726/COCH/2025[2018-19]Status: DisposedITAT Cochin19 Nov 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2018-19 Water World Tourism Company Pvt. Ltd. .......... Appellant Room No. 18, Municipal Shopping Centre Zilla Court Ward, Opp. Boat Jetty Thathampally S.O., Alappuzha 688013 [Pan: Aabcm3387L] Vs. The Income Tax Officer, Wd-1& Tps, Alappuzha ......... Respondent Assessee By: Shri Thomas Joseph, Ca Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 04.11.2025 Date Of Pronouncement: 19.11.2025

For Appellant: Shri Thomas Joseph, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 115BSection 143(3)Section 68

Water World Tourism Company Pvt. Ltd. Against the said return of income, the assessment was completed by the National Faceless Assessment Centre, Delhi [CIT(A)] (hereinafter called "the AO") vide order dated 17.09,2021 passed u/s. 143(3) r.w.s. 144B of the Income

Santosh Shankar Gujar, Laxmi Nagar, Thergaon vs. Income Tax Officer, Ward 8(3), Pune, Akurdi

In the result, the appeal filed by the assessee in ITA

ITA 2038/PUN/2024[2013 - 2014]Status: DisposedITAT Pune19 Nov 2025

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1654 & 2038/Pun/2024 िनधा"रण वष" / Assessment Years : 2014-15 & 2013-14 Santosh Shankar Gujar, Vs. Ito, Ward-8(3), Pune. H/No.246, Shiv Parvati Bunglow, Laxmi Nagar, Thergaon- 411033. Pan : Alnpg9944K Appellant Respondent Assessee By : Mrs. Vibha D. Gulabani Revenue By : Shri Umesh Phade Date Of Hearing : 02.09.2025 Date Of Pronouncement : 19.11.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2024 & 29.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2014-15 & 2013-14 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals, We Proceed To Dispose Of The Same By This Common Order. 3. First We Shall Take Up The Appeal Of The Assessee In Ita No.1654/Pun/2024 For A.Y. 2014-15 For Adjudication.

For Appellant: Mrs. Vibha D. GulabaniFor Respondent: Shri Umesh Phade

Section 139Section 142(1)Section 143(2)Section 144Section 147Section 148Section 2(47)Section 250Section 45Section 54F

notice u/s 148 of the Act. Another notice u/s 142(1) was issued to the assessee on 08.07.2021. Subsequently, the proceedings were transferred to Faceless Assessment Unit and another notice u/s 142(1) was issued to the assessee on 29.11.2021. The assessee comply to the above notice and submitted that ... assessment year 2014-15 was furnished before the Assessing Officer. On 07.03.2022 another notice u/s 142(1) was issued to the assessee by the Faceless Assessment Unit and the assessee in compliance to the same furnished on 24.03.2022 relevant details such as sale deed, purchase dates, rental agreements etc. After

Santosh Shankar Gujar, Near Vitthal Rukmini Mandir vs. Income Tax Officer, Ward 8(3), Pune, Akurdi

In the result, the appeal filed by the assessee in ITA

ITA 1654/PUN/2024[2014 - 2015]Status: DisposedITAT Pune19 Nov 2025

For Appellant: Mrs. Vibha D. GulabaniFor Respondent: Shri Umesh Phade

Section 139Section 142(1)Section 143(2)Section 144Section 147Section 148Section 2(47)Section 250Section 45Section 54F

M/S. N G Brothers, Kolkata vs. A.C.I.T., Circle - 40, Kolkata

In the result, all the appeals of the assessee are allowed

ITA 1881/KOL/2024[2016-2017]Status: DisposedITAT Kolkata19 Nov 2025AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Madhumita Das, DR

Section 133(6)Section 147Section 148Section 271(1)(c)Section 68

penalties were levied u/s 271(1)(c) of the Act by the NFAC (national Faceless Assessment Centre), Delhi for A.Y. 2014-15 and 2015-16 vide even order dated 15.06.2021. 2. As the facts and circumstances are similar in all the appeals and these all relates to the same assessee