“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

Suresh Auto Deal, Mumbai vs. Income Tax Officer Ward 3(1), Kalyan

In the result, appeal of the assessee is disallowed

ITA 4067/MUM/2025[2018-19]Status: DisposedITAT Mumbai16 Oct 2025AY 2018-19

Bench: Shri Pawan Singh & Smt.Renu Jauhrisuresh Auto Deal Vs. Income-Tax Officer Plot No. A-129, Opp Ward 3(1), Kalyan Auditorium, Midc, 421301. Dombivali-421201. "थायी लेखा सं./जीआइआर सं./Pan/Gir No:Abdfs7872A Appellant .. Respondent

For Appellant: Shri Rajiv KhandelwalFor Respondent: Shri Swapnil Choudhary- Sr. AR

Section 143(3)Section 148Section 250

National Faceless Appeal Centre, Delhi (hereinafter referred to as the CIT(A)) erred in upholding the action of the Assessment Unit at the National Faceless Assessment Centre, Delhi (hereinafter referred to as the Assessing Officer) in disallowing sales promotion P a g e | 2 expenses Rs 46,94,812 paid

Surendra Jain, Ssangam Nagar, Indore vs. ITO Faceless Assessment Centre, Aayakar Bhawan, White Church Road

Appeals are allowed for statistical purpose

ITA 70/IND/2025[2016-17]Status: HeardITAT Indore15 Oct 2025AY 2016-17

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 142(1)Section 144Section 147Section 148Section 69A

Appeals)- National Faceless Appeal Centre, Delhi [“CIT(A)”] which in turn arises out of respective assessment-orders dated 22.03.2022 passed by learned National Faceless Assessment Centre, Delhi [“AO”] u/s 147 r.w.s. 144 and 144B of Income-tax Act, 1961 [“the Act”] for Assessment-Years

Surendra Jain, Indore vs. ITO Faceless Assessment Centre, Income Tax Department

Appeals are allowed for statistical purpose

ITA 69/IND/2025[2017-18]Status: HeardITAT Indore15 Oct 2025AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 142(1)Section 144Section 147Section 148Section 69A

Harmit Kaur, Yamunanagar vs. ITO, Ward-3, Yamunanagar

In the result, the appeal of the assessee is allowed

ITA 981/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh15 Oct 2025AY 2020-21

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Avneet Singh &For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 147Section 148Section 151A

reassessment proceedings lacked authority in view of CBDT Notification No. 18/2022 dated 29.03.2022 issued under section 151A of the Act, whereby the National Faceless Assessment Centre (NPAC) alone was empowered to issue and process such notices. 3. Briefly the facts of the case are that the Jurisdictional AO, Ward ... issued on 26.03.2024 by the Jurisdictional AO. The CBDT Notification dated 29.03.2022 issued under section 151A clearly provides that the scheme of faceless assessment shall apply “from the stage of issuance of notice under sections 148 and 148A” and that such proceedings shall be carried out through the National Faceless

Ramesh Sistla, Hyderabad vs. ITO., Ward-14(1), Hyderabad

ITA 45/HYD/2025[2015-16]Status: DisposedITAT Hyderabad15 Oct 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdia

For Appellant: CA Y. V. Bhanu Narayan RaoFor Respondent: Dr.Narendra Kumar Naik, CIT(DR)

Section 115BSection 147Section 148Section 148ASection 234ASection 234BSection 250Section 68Section 69A

been held that as per the amended provisions w.e.f 1.4.2021 notices u/s 148 can be only given by the officers of the faceless assessment unit and as such the notice u/s 148 issued by the Jurisdictional Assessing Officer is without Jurisdiction. Hence, the income determined/additions made by the learned ... submitted that both the notice and the order were issued by the Jurisdictional Assessing Officer (“JAO”) instead of the Faceless Assessing Officer (“FAO”), which is contrary to the scheme of faceless reassessment introduced by the CBDT. 7. The Ld. AR invited our attention to the order under section 148A

Cognizance Constructions Private Limited, Hyderabad vs. ITO., Ward-1(1), Hyderabad

In the result, appeal of the Assessee is allowed for

ITA 344/HYD/2025[2013-14]Status: DisposedITAT Hyderabad15 Oct 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.344/Hyd/2025 निर्धारण वर्ष/Assessment Year 2013-2014 | M/S. Cognizance | Constructions Private | Limited, Hyderabad. | Pin – 500 075. Telangana. | Pan Aadcc1366M | (Appellant) Vs. The Income Tax Officer, Ward-1(1), Hyderabad. Telangana. (Respondent) निर्धारिती द्वारा/Assessee By: Ca Srinivas Maddury राजस्व द्वारा / Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख /Date Of Hearing: 13.10.2025 घोषणा की तारीख /Pronouncement: 15.10.2025 आदेश/Order Per Vijay Pal Rao: This Appeal By The Assessee Is Directed Against The Order Dated 17.12.2024 Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac], Delhi, For The

For Appellant: CA Srinivas MadduryFor Respondent: : Dr. Sachin Kumar, Sr. AR

Section 139Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(b)Section 271(1)(c)Section 271ASection 271F

Income Tax Officer Ward 1(1) Hyderabad. However, the assessment is taken up and completed by Additional/Joint/Deputy/Assistant Commissioner of Income Tax/Income-tax Officer, National Faceless Assessment Centre, which is against the laid legal principle that that assessment cannot be completed under borrowed satisfaction. 5. Ld.AO/NFAC erred in issue of notice

Honeywell Exim Private Limited, New Delhi vs. ACIT, Circle-10(1), Delhi

In the result the appeal of the assessee is allowed”

ITA 6033/DEL/2024[2015-16]Status: DisposedITAT Delhi15 Oct 2025AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2015-16 Honeywell Exim Private Vs. Acit, Limited, House No. 121, Circle-10(1), A Pkt., B-04, Keshavpuram. Delhi New Delhi-1100 35 1100 07 Pan: Aadch3719B (Appellant) (Respondent)

For Appellant: Shri Ved Jain, Adv. , Shri Pawan Garg and Ms. Ishika Dua, CAsFor Respondent: Shri Sanjeev Kaushal, CIT (DR)

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 148ASection 151Section 250

VIMAL KUMAR, JUDICIAL MEMBER: The appeal of assessee is against order dated 16.10.2024 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

Tupperware India Private Limited, Connaught Place New Delhi vs. National Faceless Assessment Centre Through Deputy Commissioner of Income Tax, Ip Estate New Delhi

The appeal is allowed partly

ITA 4475/DEL/2024[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year : 2020-21

Section 143(3)Section 37Section 92BSection 92C

DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Assessment Year : 2020-21 Tupperware India Private Limited, Vs National Faceless Assessment 204-206, Tolstoy House, Centre, 15 Tolstoy Marg, New Delhi. through Connaught Place, DCIT, Circle 25(1), New Delhi-110001. New Delhi. PAN: AAACT3770

Himalaya Realestate Private Limited, Shakti Nagar vs. Assistant Commissioner of Income Tax Circle 11(2), Delhi, Cr Building

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

ITA 3426/DEL/2024[2017-18]Status: DisposedITAT Delhi15 Oct 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 Himalaya Realestate Private Vs. Assistant Commissioner Of Income Limited, 7365, Shakti Nagar, Tax, Circle 11(2), Delhi – 1100 07 Delhi Pin: 1100 02 Pan :Aacch6225K (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 234BSection 234CSection 250Section 271ASection 68

VIMAL KUMAR, JUDICIAL MEMBER: The appeal filed by the assessee is against order dated 17.10.2023 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

Santosh Rathore, Indore vs. Principal Commissioner of Income Tax, Indore - 1, Indore

Appeal is allowed

ITA 451/IND/2024[2015-16]Status: DisposedITAT Indore14 Oct 2025AY 2015-16

Bench: Shri B.M. Biyani

Section 139Section 143(2)Section 147Section 148Section 151Section 263

PCIT”] u/s 263 of Income-tax Act, 1961 [“the Act”] which in turn arises out of assessment-order dated 24.03.2022 passed by learned National Faceless Assessment Centre [“AO”] u/s 147 r.w.s. 144B of the act for Assessment-Year [“AY”] 2015-16, the assessee has filed this appeal on following grounds ... exercising the provisions of Section 263 of the Act in respect of the reassessment order dated 24.03.2022 has been passed by the Ld. National Faceless Assessment Centre (‘the Ld. NaFAC’) and the jurisdiction u/s. 263 of the Act cannot be exercised in respect of Order passed by the Ld. NaFAC

Jashwantbhai Mahijibhai Baria, Panchmahal vs. ITO, Ward 1, Godhra

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

ITA 1585/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad14 Oct 2025AY 2019-20

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: NoneFor Respondent: Shri Sudhakar Verma, Sr. DR

Section 147Section 148Section 148ASection 153CSection 270ASection 69

Asst. Year : 2019-20 - 2– 2. The learned CIT(A) erred in fact and in law in confirming the action of learned AO, National Faceless Assessment Centre (“the AO”) in passing the order which is invalid in law and therefore liable to be quashed. Without prejudice to the above: Invalid

Thanaraj Sumathi, Mayiladuthurai vs. ITO, Ward-1, Kumbakonam

In the result, appeal filed by the assessee is allowed

ITA 2031/CHNY/2025[2019-20]Status: DisposedITAT Chennai14 Oct 2025AY 2019-20

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2031/Chny/2025 यनिाारणवर्ा / Assessment Year:2019-20 Thanaraj Sumathi, Income Tax Officer, No.3/25, North Street, Vs. Ward-1 Moovalur, Kumbakonam. Mayiladuthurai – 609806. Tamil Nadu. [Pan:Knyps-1061-J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate. प्रत्यर्थीकीओरसे/Respondent By : Ms. R. Anitha, Cit. सुनवाईकीतारीख/Date Of Hearing : 13.10.2025 घोर्णाकीतारीख/Date Of Pronouncement : 14.10.2025

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. R. Anitha, CIT

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

appeal, the preliminary issue to be decided is whether the assumption of jurisdiction for reopening the assessment by Jurisdictional Assessment Officer(JAO) as against Faceless Assessment Officer (FAO) could be considered as valid. This goes to the root of the matter and hence we deem it fit to address this ... What is covered in clause 3(a) of the Scheme is already provided in Section 144B(1) of the Act, which Section provides for faceless assessment, and covers assessment, reassessment or recomputation under Section 147 of the Act. Therefore, if Revenue's arguments are to be accepted, there

Rivaara Labs Private Limited, Mumbai vs. Principal Commissioner of Income Tax -3, Mumbai

In the result, the appeal of the assessee is allowed

ITA 3640/MUM/2025[2021-22]Status: DisposedITAT Mumbai14 Oct 2025AY 2021-22

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Nishit Gandhi,ARFor Respondent: Shri Uma Shankar Prasad, (CIT-DR)

Section 143(3)Section 263Section 35DSection 37Section 37(1)

PCIT erred in invoking the provisions of section 263 by treating the assessment order under section 143(3) by the Assessment Unit, National Faceless Assessment Center ( the AO) as erroneous and prejudicial to the interests of the Revenue, without appreciating that the AO had duly enquired into the issues, conducted

DCIT- 27(2), Mumbai, Vashi, Navi Mumbai vs. Nayan Builders, Ghatkopar East, Mumbai

In the result, the appeal filed by the revenue is dismissed in above

ITA 4039/MUM/2023[201819]Status: DisposedITAT Mumbai14 Oct 2025

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 115BSection 250Section 68

estate and has shown income from business or profession and income from other sources. The case was selected for limited scrutiny through CASS under faceless assessment scheme (FAS) to verify i) Income from Real Estate Business, ii) Unsecured Loans and iii) Business Expenses. Regarding the unsecured loan, assessee was asked

Ananda Aqua Exports, Ganapavaram vs. Income Tax Officer, Ward-1, Bhimavarm

ITA 15/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam13 Oct 2025AY 2017-18

Section 143(3)Section 148Section 148ASection 149(1)(b)Section 250Section 250(6)Section 69Section 69A

Income Tax Officer, Ward-1, Bhimavaram, were contrary to the statutory provisions governing the time limitation for assessment, as well as the requirements of faceless assessment. Therefore, the appellant asserts that the proceedings conducted by the local jurisdictional officer are void-ab- initio. 10. Without prejudice to ground

Surender Singh Deswal, Panchkula vs. Dy. Commissioner of Income Tax, Circle, Pkl, Panchkula

The appeal stand allowed in terms of our above order

ITA 672/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh13 Oct 2025AY 2016-17

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.672/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2016-17) Shri Surender Singh Deswal Dcit-Circle Panchkula बनाम/ Vs. 1411, Sector 21 Sector-2 Panchkula-134112 Panchkula-134112 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Adspd-1925-A (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashok Goyal (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl.Cit) – Ld. Sr. Dr

For Appellant: Shri Ashok Goyal (CA) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl.CIT) – Ld. Sr. DR

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

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 asserted that in terms of ratio of various decisions of jurisdictional High Court, issuance of notice u/s 148 by Jurisdictional ... Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO) would vitiate the assessment proceedings. The Ld. Sr. DR opposed admission of any such ground at this stage of proceedings. 4. The undisputed fact that emerges is that notice u/s 148 has been issued on 30-03-2022 by Jurisdictional Assessing

Incometax Officer, Ward-3(1), Visakhapatnam vs. Surendra Nath Gubbala, Visakhapatnam

ITA 482/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam10 Oct 2025AY 2020-21

Bench: Us:

Section 143(3)Section 144BSection 48

revenue has assailed the impugned order on the following grounds of appeal before us: “1. The order of the Ld. CIT(A), National Faceless Assessment Centre (NFAC) is erroneous both on facts and in law. 2.1. The Ld. CIT(A) erred in deleting the addition of Rs.9

Nitu Khadariya, Jaipur vs. ITO Ward 1(3), Ncrb Building

In the result, the appeal of the assessee is allowed

ITA 1360/JPR/2024[2014-15]Status: DisposedITAT Jaipur09 Oct 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri C.L. Yadav, CAFor Respondent: Shri Gautam Singh Choudhary,JCIT-DR

Section 143(3)Section 144BSection 147Section 69A

year 2014-15. That order of the ld. CIT(A) arise because the assessee challenged the assessment order dated 27.03.2022 passed by the National Faceless Assessment Centre ( Delhi ) [ for short AO ]passed as per provisions of section 147 r.w.s. 144 with section 144B of the Income ... Whether impugned notice dated 1st May 2024 is invalid and bad in (B) law being issued by Jurisdictional Assessing Officer (JAO) and not Faceless Assessing Officer (FAO)? (C) Whether the issues raised in impugned order show an alleged escapement of income represented in the form of an asset or expenditure

Bhawani Developers, Lucknow vs. Income Tax Officer-4(1), Lucknow-New

Appeal is disposed of in accordance with the aforesaid

ITA 253/LKW/2025[2018-19]Status: DisposedITAT Lucknow09 Oct 2025AY 2018-19

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 115BSection 133(6)Section 142(1)Section 144BSection 147Section 68

jurisdictional issues have been raised. The submission is that the jurisdictional assessing authority could not have issued the said notices/orders, it is only the faceless assessing authority who could have done it. Mr. Pradeep Agrawal says that instead of entering into the merits of the issues the appellate authority should ... Madras) it has been decided that notice issued u/s 148 by the JAO was legal and as per the scheme of faceless assessment. Hon'ble Madras High Court. 7 The Delhi High Court in TKS Builders Pvt Ltd (supra) has decided that The CBDT has conferred power upon the incometax

Rajendraa Sakunthala, Coimbatore vs. ACIT, Ncc-2, Coimbatore

In the result, appeal filed by the assessee is allowed

ITA 1624/CHNY/2025[2018-19]Status: DisposedITAT Chennai09 Oct 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. Sudharshan, Advocate for Shri. S. Sridhar, AdvocateFor Respondent: Ms. E. Pavuna Sundari, C.I.T

Section 139(1)Section 147Section 148Section 148ASection 50C

order u/s.147 of the Income Tax Act, 1961 [hereinafter referred to :-2-: ITA. No.:1624 /Chny/2025 as “the Act”) passed by the National Faceless Assessment Centre [hereinafter referred to as the “AO”] dated 24.03.2023. 2. At the threshold, we observe that there is a delay of 34 days ... 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 :-11-: ITA. No.:1624 /Chny/2025 batch cases, followed